Task 7 report SCENARIOS · 2019-10-29 · Task 7 report SCENARIOS Final version Date: May 2018 . 2...

1

Review of Regulation 206/2012 and

626/2011

Air conditioners and comfort fans

Task 7 report

SCENARIOS

Final version

Date: May 2018

2

Prepared by:

Viegand Maagøe and ARMINES

Study team: Baijia Huang, Jan Viegand, Peter Martin Skov Hansen, Philippe Riviere

Quality manager: Jan Viegand

Website design and management: Viegand Maagøe A/S

Contract manager: Viegand Maagøe A/S

Prepared for:

European Commission

DG ENER C.3

Office: DM24 04/048

B-1049 Brussels, Belgium

Contact person: Veerle Beelaerts

E-mail: [email protected]

Project website: www.eco-airconditioners.eu

Specific contract no.: No. ENER/C3/FV 2016-537/03/FWC 2015-619

LOT2/01/SI2.749247

Implements Framework Contract: № ENER/C3/2015-619 LOT 2

This study was ordered and paid for by the European Commission, Directorate-General

for Energy.

The information and views set out in this study are those of the author(s) and do not

necessarily reflect the official opinion of the Commission. The Commission does not

guarantee the accuracy of the data included in this study. Neither the Commission nor any

person acting on the Commission’s behalf may be held responsible for the use which may

be made of the information contained therein.

This report has been prepared by the authors to the best of their ability and knowledge.

The authors do not assume liability for any damage, material or immaterial, that may arise

from the use of the report or the information contained therein.

© European Union, May 2018.

Reproduction is authorised provided the source is acknowledged.

More information on the European Union is available on the internet (http://europa.eu).

Viegand Maagøe A/S

Nr. Farimagsgade 37

1364 Copenhagen K

Denmark

viegandmaagoe.dk

http://www.eco-airconditioners.eu/

http://viegandmaagoe.dk/

3

Table of contents List of tables ......................................................................................................... 4

List of figures ........................................................................................................ 6

Abbreviations ........................................................................................................ 8

Introduction to the task reports ............................................................................... 9

7 Introduction to Task 7 .....................................................................................11

7.1 Policy analysis ...........................................................................................11

7.1.1 Stakeholder consultation.......................................................................11

7.1.2 Barriers and opportunities for improvements ...........................................12

7.1.3 Policy options ......................................................................................13

7.1.4 Recommended policy measures .............................................................14

7.1.5 Metrics changes ...................................................................................23

7.1.6 Proposed tolerances and uncertainties ....................................................27

7.2 Scenario analysis.......................................................................................32

7.2.1 Before EU regulation – 0 scenario ..........................................................33

7.2.2 Business-as-Usual (BAU) - scenario 1 .....................................................35

7.2.3 Policy scenarios ...................................................................................39

7.3 Impact analysis for consumers and industry .................................................44

7.3.1 Consumer impacts ...............................................................................44

7.3.2 Industry impacts..................................................................................47

7.4 Sensitivity analysis ....................................................................................49

7.5 Comparison of air-to-air heat pumps and other heating products.....................50

7.6 Conclusions and recommendations ..............................................................50

Annex 1 – Comfort fans assessment ....................................................................60

Annex 2 – Policy scenarios assumptions ...............................................................69

Annex 3 – Tables and figures ..............................................................................70

4

List of tables Table 1: Proposed minimum efficiency requirements for air conditioners in a potential

revised ecodesign regulation ..................................................................................14

Table 2: Proposed new label schemes for SEER ........................................................17

Table 3: Proposed new label scheme for SCOP .........................................................18

Table 4: Proposed new label schemes for a combined label ........................................19

Table 5: Discussion on material efficiency improvements options presented in Task 4. ..21

Table 6: Alignment with other regulations ...............................................................22

Table 7: Measurement uncertainty calculation results for 6 split units of different sizes. 30

Table 8: Measurement uncertainty calculation results for 2 single duct units of different

sizes ...................................................................................................................31

Table 9: Summary of policy scenarios and brief descriptions ......................................33

Table 10: Development of SEER and SCOP of air conditioners sold - with no EU regulation

..........................................................................................................................33

Table 11: The annual energy consumption and emission of CO2-eq in scenario 0 (no

intervention from EU) ...........................................................................................34

Table 12: Development of SEER and SCOP with the current regulation ........................35

Table 13: The annual energy consumption and emission of CO2-eq in scenario 1 (current

regulation) ..........................................................................................................37

Table 14: The accumulated savings in energy and emission of CO2-eq in scenario 1

(effect of current regulation) compared to scenario 0 ................................................37

Table 15: Impacts of scenario 2 (1 tier eco) – Annual savings compared to scenario 1

(current regulation) in TWh, Primary energy and CO2-eq ...........................................43

Table 16: Impacts of scenario 3 (lbl) - Annual savings compared to scenario 1 (current

regulation) in TWh, Primary energy and CO2-eq .......................................................43

Table 17: Impacts of scenario 4 (eco+lbl) - Annual savings compared to scenario 1

(current regulation) in TWh, Primary energy and CO2-eq ...........................................43

Table 18: Total annual consumer expenditures in absolute values and annual savings

compared with 1 BAU current regulation..................................................................47

Table 19: Assumptions to model to industry impacts. ................................................47

Table 20: The calculated impacts of higher levels of recycling and the effect of higher

leakage. ..............................................................................................................49

Table 21: Summary of policy scenarios and brief descriptions ....................................51

Table 22: Proposed minimum efficiency requirements for air conditioners in a potential

revised ecodesign regulation ..................................................................................51

Table 23: Proposed new label schemes for SEER ......................................................52

Table 24: Proposed new label scheme for SCOP .......................................................52

Table 25: Proposed new label schemes for a combined label ......................................53

Table 26: The annual electricity consumption, emission of CO2-eq and associated savings

in 2030 ...............................................................................................................54

Table 27: The annual electricity consumption, emission of CO2-eq and associated savings

in 2040 ...............................................................................................................55

Table 28: Prodcom categories covering products relevant for this study. .....................60

Table 29: Suggested minimum requirements in the preparatory study ........................66

Table 30: LLCC and BAT for different types of comfort fans - based on the preparatory

study ..................................................................................................................66

Table 31: Assumptions in all scenarios ....................................................................69

Table 32: Development of SEER and SCOP average sales values in the different

scenarios. ............................................................................................................70

5

Table 33: Impacts of scenario 0 (before regulation) - TWh, Primary energy and CO2-eq in

absolute values ....................................................................................................71

Table 34: Impacts of scenario 1 (current regulation) - TWh, Primary energy and CO2-eq

in absolute values .................................................................................................71

Table 35: Impacts of scenario 2 (1 tier eco) - TWh, Primary energy and CO2-eq in

absolute values ....................................................................................................72

Table 36: Impacts of scenario 3 (lbl) - TWh, Primary energy and CO2-eq in absolute

values .................................................................................................................72

Table 37: Impacts of scenario 4 (eco+lbl) - TWh, Primary energy and CO2-eq in absolute

values .................................................................................................................72

Table 38: The accumulated savings in energy and emission of CO2-eq of the policy

options compared to the current regulation (scenario 1) ............................................73

Table 39: Development in purchase price per unit in absolute values ..........................74

Table 40: Annual consumer purchase costs of air conditioners in absolute values .........74

Table 41: Annual consumer electricity costs in absolute values ...................................75

Table 42: Annual installation and maintenance costs in absolute values ......................75

Table 43: Industry impacts - Manufacturer turnover (Mln EUR) ..................................75

Table 44: Industry impacts - Manufacture total personnel (Persons) ...........................76

Table 45: Industry impacts - OEM total personnel (Persons) ......................................76

Table 46: Industry impacts - OEM total personnel – EU (Persons) ...............................76

Table 47: Industry impacts - Wholesaler turnover (Mln EUR) .....................................76

Table 48: Industry impacts - Wholesaler total personnel (Persons) ............................77

Table 49: The calculated impacts of higher levels of recycling and the effect of higher

leakage in absolute values. ....................................................................................77

6

List of figures Figure 1: Current minimum efficiency requirement set by Regulation 206/2012 ...........15

Figure 2 Current energy efficiency classes for air conditioners other than single and

double ducts set by Regulation 626/2011 ................................................................16

Figure 3: Current energy efficiency classes for single and double ducts set by Regulation

626/2011 ............................................................................................................17

Figure 4: Example of proposed energy label for single and double duct units (not final

revised label), example of expressing sound power level in a scale of A-G (middle), and

example of sound power level expressed by pictograms of sound waves used by tyre

labels (left). .........................................................................................................18

Figure 5: ECC directory 2006, air conditioners below 12 kW, sound power level of indoor

unit in cooling mode .............................................................................................34

Figure 6: ECC directory 2006, air conditioners below 12 kW, sound power level of

outdoor unit in cooling mode ..................................................................................35

Figure 7: Comparison of the annual energy consumption of scenario 0 and scenario 1. .36

Figure 8: Comparison of the annual emission of CO2-eq in scenario 0 and scenario 1. ...36

Figure 9: Comparison of the indoor sound power level in 2006 (blue dots and) and 2016

(Green dots) ........................................................................................................38

Figure 10: Comparison of the outdoor sound power level in 2006 (blue dots and) and

2016 (Green dots) ................................................................................................38

Figure 11: Comparison of the SEER development for BC1 in all scenarios ....................39

Figure 12: Comparison of the SEER development for B2 in all scenarios ......................39

Figure 13: Comparison of the SEER development for BC3 in all scenarios ....................40

Figure 14: Comparison of the SCOP development for BC1 in all scenarios ....................40

Figure 15: Comparison of the SCOP development for BC2 in all scenarios ....................41

Figure 16: Comparison of the annual energy consumption of three base cases in all

scenarios .............................................................................................................42

Figure 17: Comparison of the annual emission of CO2-eq of three base cases in all

scenarios .............................................................................................................42

Figure 18: The accumulated savings in electricity (TWh) and emission of CO2-eq of the

policy options compared to the current regulation (scenario 1) ...................................44

Figure 19: The accumulated savings in emissions of CO2-eq of the policy options

compared to the current regulation (scenario 1) .......................................................44

Figure 20: Annual consumer purchase costs of air conditioners in absolute values ........45

Figure 21: Annual consumer electricity costs in absolute values .................................46

Figure 22: Total annual consumer expenditures in absolute values .............................46

Figure 23: Industry turnover per year for different policy scenarios ............................48

Figure 24: Number of personnel in air conditioner industry for different policy scenarios49

Figure 25: Total production, import and export quantity of comfort fans below 125 W

2009-2015. PRODCOM assessed April 2017. ............................................................61

Figure 26: Total EU sales and trading of comfort fans below 125 W 2009-2015.

PRODCOM assessed April 2017. ..............................................................................61

Figure 27: Comparison of EU sales and trading of comfort fans below 125 W 2009-2015

of current PRODCOM data (assessed April 2017) and expected sales and trades from the

preparatory study .................................................................................................62

Figure 28: Assumed stock development - preparatory study ......................................62

Figure 29: Types of comfort fans - assumption from the preparatory study ..................63

Figure 30: Spread in wattage and service values of comfort fans ................................64

Figure 31: Spread in service values of the different types of comfort fans ....................64

7

Figure 32: LLCC from the preparatory study and current service value. .......................67

Figure 33: Comparison of impacts of the different scenarios – Primary energy (PJ) in

absolute values ....................................................................................................70

Figure 34: Comparison of impacts of the different scenarios – Emission of CO2 (Mt) in

absolute values ....................................................................................................71

Figure 35: The accumulated savings in primary energy (PJ)of the policy options

compared to the current regulation (scenario 1) .......................................................73

8

Abbreviations

BAT Best Available Technology

BAU Business as Usual

BC Base cases

BEP Break-Even Point

BNAT Best Not yet Available Technology

COP

Coefficient of Performance for air conditioners in

heating mode

ECC Eurovent Certita Certification

ηs,c

Greek letter eta, denoted by s,c, means primary

seasonal space cooling efficiency

ηs,h

Greek letter eta, denoted by s,h, means primary

seasonal space heating efficiency

EER

Energy Efficiency Ratio for air conditioners in

cooling mode

GWP Global warming potential

LLCC Least Life Cycle Cost

RRT Round Robin Test

SEER

Seasonal Energy Efficiency Ratio for air

conditioners, cooling mode

SCOP

Seasonal Coefficient of Performance for air

conditioners, heating mode

9

Introduction to the task reports This is the introduction to the Review of Regulation 206/2012 and 626/2011 for air

conditioners and comfort fans. The report has been split into seven tasks, following the

structure of the MEErP methodology. Each task report has been uploaded individually in

the project’s website. These task reports present the technical basis to define future

ecodesign and energy labelling requirements based on the existing Regulation (EU)

206/2012 and 626/2011.

The task reports start with the definition of the scope for this review study (i.e. task 1),

which assesses the current scope of the existing regulation in light of recent developments

with relevant legislation, standardisation and voluntary agreements in the EU and abroad.

Furthermore, assessing the possibility of merging implementing measures that cover the

similar groups of products or extend the scope to include new product groups. The

assessment results in a refined scope for this review study.

Following it is task 2, which updates the annual sales and stock of the products in scope

according to recent and future market trends and estimates future stocks. Furthermore, it

provides an update on the current development of low-GWP alternatives and sound

pressure level.

Next task is task 3, which presents a detailed overview of use patterns of products in scope

according to consumer use and technological developments. It also provides an analysis of

other aspects that affect the energy consumption during the use of these products, such

as component technologies. Furthermore, it also touches on aspects that are important for

material and resource efficiency such as repair and maintenance, and it gives an overview

of what happens to these products at their end of life.

Task 4 presents an analysis of current average technologies at product and component

level, and it identifies the Best Available Technologies both at product and component level.

An overview of the technical specifications as well as their overall energy consumption is

provided when data is available. Finally, the chapter discusses possible design options to

improve the resource efficiency.

Simplified tasks 5 & 6 report presents the base cases, which will be later used to define

the current and future impact of the current air condition regulation if no action is taken.

The report shows the base cases energy consumption at product category level and their

life cycle costs. It also provides a high-level overview of the life cycle global warming

potential of air conditioners and comfort fans giving an idea of the contribution of each life

cycle stage to the overall environmental impact. Finally, it presents some identified design

options which will be used to define reviewed ecodesign and energy labelling requirements.

Task 7 report presents the policy options for an amended ecodesign regulation on air

conditioners and comfort fans. The options have been developed based on the work

throughout this review study, dialogue with stakeholders and with the European

Commission. The report presents an overview of the barriers and opportunities for the

reviewed energy efficiency policy options, and the rationale for the new

material/refrigerant efficiency policy options. This report will be the basis to calculate the

estimated energy and material savings potentials by implementing these policy options, in

comparison to no action (i.e. Business as Usual – BAU).

10

The task reports follow the MEErP methodology, with some adaptations which suit the

study goals.

11

7 Introduction to Task 7 In task 7, a number of policy scenarios will be established based on the analyses and

stakeholder consultations. Task 7 presents the ecodesign and energy labelling

requirements, both for energy efficiency and for material efficiency. The focus will be on

updating the existing regulations in terms of updating requirements and possible new

requirements, e.g. energy efficiency, the use of low-GWP refrigerants, etc. Moreover,

feasibility of policy options that address durability, reparability, disassembly and

recyclability is analysed.

The scenarios together with a Business-As-Usual scenario is modelled for the period from

2015 until 2030, including sensitivity analyses.

The task is concluded with a summary of the work undertaken in Task 7, with an overview

of both positive and negative impacts related to each policy scenario as well as a set of

recommendations.

This task report includes the following:

1. Overview of the barriers and opportunities for the suggested policy measures, focusing

on ecodesign energy requirements and energy labelling.

2. Definition of proposed scope for ecodesign and energy labelling requirements.

3. Definition of policy measures for energy requirements, including timing and target

levels.

4. Definition of material efficiency requirements, including the rationale for defining these

requirements.

5. Scenario analyses presenting the effect of implementing the energy requirements.

6. Sensitivity analyses of the main parameters in the scenario analysis.

7.1 Policy analysis

According to MEErP and based on the results of the policy analysis, a (package of) policy

instrument(s) should be selected and the impacts of the policy scenario(s) should be

assessed on the energy system, the end-user and on industry in comparison with the

impacts of the BAU scenario.

7.1.1 Stakeholder consultation

Stakeholders have been contacted and consulted from the very beginning of the study.

Various industry stakeholders have supplied technical specifications of current average

products, best available product on the market and best available technology (BAT).

Consultation on material efficiency has also been carried out to assess the feasibility and

needs for ecodesign policy interventions. Detailed market data and prices have been

purchased from market intelligence company such as GfK1 and BSRIA2, and much of the

analysis regarding efficiencies, sound power level, other technical parameters are based

on the datasets from Eurovent Certita Certification (ECC3). The analysis of efficiencies is

1 www.gfk.com 2 https://www.bsria.co.uk 3 http://www.eurovent-certification.com/. ECC is a certification company and includes a certification program for less than 12 kW air conditioners. ECC is the only public source in Europe to find technical information on a large number of products. The less than 12 kW certification program gathers 22 manufacturers, including all major brands; all their products have to be certified (this represented about 2200 models as per November

12

updated with datasets received from industry stakeholders after the second stakeholder

meeting to make sure the result is based on sales weighted data to be more representative

of the market.

After two stakeholder meetings, many industry stakeholders, NGOs, member states and

consumer organisations have submitted comments and suggestions to the study, most of

which have been taken into consideration or incorporated.

7.1.2 Barriers and opportunities for improvements

This subsection describes briefly the barriers and opportunities for improvements

environmental impact, as well as opportunities for a revised Ecodesign measure.

Task 1 – 4 has shown that the current ecodesign and energy labelling regulations on air

conditioners and comfort fans can be improved.

Scope coverage of current regulations for certain product group is blurry and to avoid

loophole and ensure consistency with other regulations, the scope is recommended to

extend to cover ventilation exhaust air conditioners and air to air heat pumps.

Low power modes power consumption and hours have been reviewed and it is shown that

there is improvement potential to achieve lower power consumption in standby/off modes,

thermostat-off mode and crankcase heater mode. The potential has not been realised by

the industry due to the limited impact the consumption in each mode has on the overall

efficiency calculation for SEER and SCOP. An opportunity for revised ecodesign measure is

to propose to revise the weighting of the low power modes in the metrics, in order to create

a greater incentive for manufacturers to reduce the power consumption. This is also

identified as one of the improvement options to achieve higher efficiency in Task 6.

Assessment of existing average product and best available technology (BAT) shows that

there is still potential for higher efficiency of heating and cooling for fixed air conditioners

and of cooling by portable air conditioners. Least Life Cycle Cost (LLCC) assessment

revealed that the LLCC option is close to the base case, as the LCC of a few different options

are quite close to each other and the largest saving potential has already been achieved

with current regulation due to the technology of inverter. The BNAT option shows the long-

term potential, which is significant in comparison with LLCC option, although with the

current cost for improvement, it is not the most economical option. However, this shows

the level of achievable technology that could be used to set as a goal or a pulling force in

the form of energy class scale.

To balance the energy efficiency and sound power level is crucial, for fixed air conditioners

in the range of 6 – 12 kW capacity, there is a slight potential to lower the maximum sound

power level requirement, whereas other air conditioners have no margin to achieve lower

sound power at the same time achieve a higher minimum efficiency requirement as

proposed.

To be able to better compare single and double duct air conditioners with others, it is

suggested to split double duct air conditioners in two distinct categories, fix and portable

products; indeed, fix double duct air conditioners in fact compete with split air conditioners,

while portable double duct compete with single duct air conditioners. In addition, for

portable air conditioners and heat pumps, there should be a seasonal performance metrics,

2016); representativeness is believed to be high: about 80 % of products sold in Europe according to the Preparatory study.

13

and there should be a test method that includes the infiltration air flow in the measurement.

This would ensure better consumer understanding of the energy label which does not make

a distinction between single/double duct air conditioners and others, and reports a more

realistic performance at the same discourage consumers to use thermodynamic heating

with single duct products. More details in section 7.1.5.

7.1.3 Policy options

There are several product policy instruments available, which could be used to regulate air

conditioners and comfort fans. Given that there are already ecodesign and energy labelling

regulation for these products, the focus of policy options is easily identified. The basic types

of policy instruments as presented below:

1) No action option – Business as usual (BAU), the current regulations are to be

retained as they are. The first overall decision to be made is whether there is a need

for further EU intervention. This BAU scenario will be used as reference for

comparison with other policy scenarios.

2) Ecodesign requirements (under the Ecodesign Directive (2009/125/EC)): This

means mandatory minimum requirements would be introduced for a set of

parameters, the manufacturers would bear the responsibility for their products to

be compliant when placed on the market and the Member States would verify

compliance via market surveillance activities. This acts as a “push” instrument for

products to achieve better performance because all appliances will have a minimum

level of energy efficiency performance regulated by the implementing measure.

Since there is already Ecodesign regulation No 206/2012 for air conditioners and

comfort fans, this policy option will be analysed in one or more scenarios with newly

proposed requirements in this review study.

3) Energy labelling (under the Energy Labelling Regulation (2017/1369/EU)4): This

implies mandatory labelling of the product for a set of parameters. Manufacturers

are responsible for labelling their products and it is also enforced by Member State

market surveillance. This acts as a “pull” instrument because the consumers will

choose the products they want to purchase which can pull the market towards

higher energy performance. Since there is already Energy Labelling regulation No

626/2011, this policy option will be analysed in one or more scenarios with newly

proposed requirements and energy class scale.

4) Self-regulation as an alternative to Ecodesign requirements: The Ecodesign

Directive (2009/125/EC) recognizes self-regulation by industry as an alternative to

binding legislation. Self-regulation, which can be based on voluntary agreements,

is a valid alternative as long as it delivers the policy objectives set out in the

legislation faster and in a less costly manner than mandatory requirements. The

directive gives specific requirements for self-regulative measures. This option was

already discarded since preparatory study as there have been established ecodesign

and energy labelling regulations since.

5) Voluntary labelling implies manufacturers can choose whether to label their

products. In the case of ENERGY STAR 5 and Ecolabel 6 , the specifications are

established through regulations, ensuring that the labelled product belongs to the

4 Regulation (EU) 2017/1369 of the European Parliament and of the Council of 4 July 2017 setting a framework for energy labelling and repealing Directive 2010/30/EU 5 Regulation (EC) No 106/2008 of the European Parliament and of the Council of 15 January 2008 on a Community energy-efficiency labelling programme for office equipment (recast version) 6 Regulation (EC) No 66/2010 of the European Parliament and of the Council of 25 November 2009 on the EU Ecolabel

14

upper segment of the market in terms of energy consumption and other

environmental aspects. Member States are responsible for market surveillance. The

US ENERGY STAR covers air conditioners, but it is not in scope of the EU-US ENERGY

STAR agreement (covers only office equipment). However, EU Regulation

66/2010/EC7 for EU Ecolabel already covers air conditioners under heat pumps8,

therefore this policy option will not be further analysed in detail.

In conclusion, policy options 1, 2 and 3 will be analysed further in the later sections of this

task.

7.1.4 Recommended policy measures

In this section, policy measures assessed in previous section as feasible options are

selected for further analysis, including timing and target levels. In the following subsection,

the discussions include whether there should be revised ecodesign requirements, such as

minimum (or maximum) requirements, and whether it should be complemented with

revised energy labelling schemes, needs for new standards to be developed as well as the

existing measurement standards that could be used and lastly possibility of setting material

efficiency requirements and information requirements on installation of the product or

other user information.

7.1.4.1 Ecodesign requirements

LLCC identified in the Task 6 and used for setting the immediate minimum requirement for

ecodesign.

For portable air conditioners, it is also recommended to set minimum ecodesign

requirements based on seasonal performance metrics (SEER and SCOP) for portable air

conditioners as well using the proposed metrics as transitional method.

It is proposed the following ecodesign requirements and timing:

• Tier 1: from 2021, minimum efficiency requirement with one tier based on BC:

o LLCC for BC 1 (BC): SEER= 6.0, SCOP= 4.0, LCC = 3521€

o LLCC for BC 2 ((10% UA cond): SEER= 5.5, SCOP= 3.9, LCC = 6391€

o LLCC for BC 3 (HE1): SEER= 2.3, LCC = 602€, 9 years of payback time

See proposed ecodesign minimum efficiency requirements summarised in the table below.

Table 1: Proposed minimum efficiency requirements for air conditioners in a potential revised

ecodesign regulation

Tier 1, January 2023

SEER SCOP

Other than portable, < 6 kW 6 4

Other than portable, 6 – 12 kW 5.5 3.9

Portable 2.3 -

As seen in the table, it is the opinion of the study team that no SCOP minimum requirement

should be proposed for single and double duct air conditioners at this time. It is proposed

to start the development of a new standard in line with EN14825 plus infiltrations (with

default values if required). With this potential new standard in place, double duct products

will have to be improved to stay on the market to compete with performance of other

products. It is proposed that the single ducts would not be allowed to operate in

7 http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2010:027:0001:0019:en:PDF 8 http://ec.europa.eu/environment/ecolabel/eu-ecolabel-products-and-services.html

http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2010:027:0001:0019:en:PDF

http://ec.europa.eu/environment/ecolabel/eu-ecolabel-products-and-services.html

15

thermodynamic heating mode. Once performances of new double duct products for new

standard are known, then it can be evaluated how far their performances should be

increased.

It is however proposed to add ecodesign information requirement of SCOP derived using

the proposed metrics if the single and double duct air conditioners have heating function.

This means that existing requirements in the current regulation No 206/2012 for COP

should still apply beside the added information requirement.

Lastly, infiltration measurement should be proposed in the future mandate for standards.

Figure 1: Current minimum efficiency requirement set by Regulation 206/2012

As a comparison with current requirement shown in figure above, the proposed SEER

requirement for air conditioners other than portables is quite much more ambitious, while

the proposed SCOP requirement is not increased significantly from the current requirement

level, in order to ensure competitiveness with other heating products. For portable air

conditioners, the minimum requirement set for SEER of 2.3 is equal to EER of 2.93

(35°/35°).

7.1.4.2 Energy labelling requirements

BAT and BNAT identified in Task 6 are used for proposing energy efficiency classes, with

BNAT as the top level at energy class A. BNAT for different base case is derived with

simulation of improvement options, it could mean that it has higher performance than the

best available product (BAT) on the market. In light of how quickly air conditioners have

populated the current A+++ even though it is not yet introduced by the regulation, it is

proposed that Energy Class A should have a relatively high threshold level. This is however

in line with the Commission’s goal with the revised energy labelling scheme that the upper

class (A) shall be empty at the time when the regulation comes into force, therefore the

best available product on the market when the revised regulation is adopted should only

be able to achieve energy class B.

It is proposed that the following efficiency levels are used for the top energy efficiency

class of a revised energy labelling regulation:

16

• BNAT for BC 1 (all improvement options): SEER= 11.4, SCOP = 5.9, LCC= 4469 €,

25 years of payback time

• BNAT for BC 2 (all improvement options): SEER= 10.6, SCOP = 5.5, LCC= 8667,

32 years of payback time

• BNAT for BC 3 (all improvement options with R290): SEER= 4.3, LCC= 798€, 28

years of payback time

Figure 2 Current energy efficiency classes for air conditioners other than single and double ducts set by Regulation 626/2011

As a comparison with current energy efficiency class (Figure 2), the current class A+++

for air conditioners other than portables would be the proposed class C for SEER and SCOP.

The requirements are different for double duct air conditioners, depending on whether it is

portable or fixed. For portable air conditioners, the current class A+++(Figure 3) for EER

of 4.1 and above would be in the proposed class B.

17

Figure 3: Current energy efficiency classes for single and double ducts set by Regulation 626/2011

The proposed energy efficiency class is summarised in Table 2 and Table 3. Since the

current energy labelling does not distinguish the scale for 0 – 6 kW range and 6 – 12 kW

range, it is proposed to keep this approach and set the same scale for fixed air conditioners

and there is no technical reason for why larger air conditioners cannot achieve the same

BNAT levels for 0 – 6 kW range.

The class length is regular with 15 % increase for each class. This is a minimum value so

that class width is superior to maximum uncertainties implied by present version of

EN14825 standard (2016). In parallel, the study team aims at gathering stakeholders view

on the feasibility to lower these tolerances. See more about proposed tolerances and

uncertainties in section 7.1.6.

Given the extension of SCOP performances for split air conditioners, this leads to not using

F and G classes.

Table 2: Proposed new label schemes for SEER

Label scheme Other than portable air

conditioners

Portable air

conditioners

A SEER ≥ 11.5 SEER ≥ 4

B 9.7 ≤ SEER < 11.5 3.5 ≤ SEER < 4

C 8.1 ≤ SEER < 9.7 3.0 ≤ SEER < 3.5

D 6.8 ≤ SEER < 8.1 2.6 ≤ SEER < 3.0

E 5.7 ≤ SEER < 6.8 2.3 ≤ SEER < 2.6

F 4.8 ≤ SEER < 5.7 SEER < 2.3

G SEER < 4.8

18

Table 3: Proposed new label scheme for SCOP

Label

scheme

Other than portable air

conditioners

A SCOP ≥ 6.2

B 5.5 ≤ SCOP < 6.2

C 4.9 ≤ SCOP < 5.5

D 4.3 ≤ SCOP < 4.9

E 4.9 ≤ SCOP < 4.3

F SCOP < 3.8

G NA

Currently, consumers are not aware of the difference in energy efficiency when comparing

fixed and portable air conditioners as the current energy labels for both types are largely

the same. To enable better comparison, it is proposed that requirements should be set

using seasonal performance metrics for both, proposed metrics with default infiltration

values described in section 7.1.5 can be used as transitional method. However, it is the

opinion of the study team that an energy class should only be proposed for portable air

conditioners (single and double ducts) in cooling mode using proposed SEER metrics. SCOP

is to be declared on the energy label but no energy class is proposed; see an example of

visual presentation for proposed energy label in Figure 4 below. When seasonal

performance (that accounts for infiltration) of these products is widely known, an energy

class scale for SCOP can be then proposed.

Lastly, infiltration measurement should be proposed in the future mandate for standards.

Figure 4: Example of proposed energy label for portable single and double duct units (not final revised label), example of expressing sound power level in a scale of A-G (middle), and example of sound power level expressed by pictograms of sound waves used by tyre labels (left).

19

Furthermore, some stakeholders9 have suggested to establish a sound power level scale

for all heat pumps and add it on the energy label. Since the noise is an increasing concern

of the consumers, the energy label should indicate the sound power levels in a scale of A–

G or the loudness should be indicated by pictograms the sound waves already used in the

icon, tyre label can be of inspiration, see Figure 4.

Combined label scheme

For better comparison between fixed and portable air conditioners, a combined label

scheme is suggested based on primary seasonal space heating and cooling efficiency (ηs,h

and ηs,c). A combined label scheme may influence positively the effect of the label, as the

class length proposed above is elongated due to the efficiency development and it is too

difficult and costly to improve the product to a better class. Another challenge is the

difference in the SCOP and SEER calculations which means that the products not are 100

% comparable. The benefit of a combined label based on primary seasonal space heating

and cooling efficiency (ηs,h and ηs,c ) is the better comparison of products, so the consumers

can see the differences in efficiency of the different technologies.

Primary seasonal space heating and cooling efficiency is also used in e.g. Regulation (EU)

No 811/2013 for space heaters, combination heaters and Regulation (EU) No 2015/1187

for solid fuel boilers etc. Ideally, the use of ηs,h should be aligned with all relevant

regulations so all heating products can be compared.

Table 4 represents a suggestion on how the classes could be defined in a combined label

scheme. Note that SEER and SCOP are replaced with ηs,c and ηs,h . ηs,c is calculated as the

SEER value divided by the primary energy factor10 and ηs,h is calculated as the SCOP value

divided with the primary energy factor.

Table 4: Proposed new label schemes for a combined label

Label scheme ηs,c ηs,h

A ηs,c ≥ 4.6 ηs,h ≥ 2.5

B 3.3 ≤ ηs,c < 4.6 2 ≤ ηs,h < 2.5

C 2.4 ≤ ηs,c < 3.3 1.6 ≤ ηs,h < 2

D 1.8 ≤ ηs,c < 2.4 1.3 ≤ ηs,h < 1.6

E 1.3 ≤ ηs,c < 1.8 1 ≤ ηs,h < 1.3

F 0.9 ≤ ηs,c < 1.3 0.8 ≤ ηs,h < 1

G ηs,c < 0.9 ηs,h < 0.8

7.1.4.3 Comfort fans

Regarding comfort fans the same challenges still exist (since the preparatory study) and it

is further elaborated in Annex 1. Based on the findings of this assessment there are options

which are:

• Setting minimum energy efficiency requirements on comfort fans with the proposed

requirements (from the preparatory study) with the risk of banning many comfort

fans in the European market (expected savings in the preparatory study was slightly

below 1 TWh).

9 NGOs such as ANEC and BEUC, Member states such as Germany and EEA country Norway 10 Primary energy factor is assumed 2.5 until the European Commission published a new value.

20

• Enforcing better market surveillance on the current information requirement and

gathering accurate information on comfort fan efficiency and test methods through

a complementary study/efficiency tests with corresponding costs.

7.1.4.4 Material efficiency requirement

Material efficiency requirements are very difficult to model, as the material efficiency is

dependent on the waste handling system. This system can change due to commodity prices

which potentially can change the business model of shredders. If the commodity prices are

subject to a significant increase the recycling may be improved due to improved economic

incentive and vice versa. As long as the preferred recycling option is shredding all

suggestions regarding improved disassembly are not reasonable regarding improvement

in recycling rates. The affordability of repair could be improved due to design for

disassembly, but manufactures have indicated that they already are targeting to improve

the reparability so they do not believe that there is a need to include these requirements.

This was supported by exploded views of appliances where it was visible that the assembly

was proportionate simple and parts like the PCBs was easily reachable, see Table 5 for

more detail. Furthermore, air conditioners already have to comply with the requirements

in the WEEE directive, but the transposition of the directive is different in Member state.

Another challenge is the End-of-Life shredding if air conditioners are mixed with other types

of appliances (E.g. refrigerators). Then the impact of material requirements (e.g.

requirements of the type of plastic used for the casing) will be reduced as air conditioners

are mixed with other products containing different materials and the risk of contamination

will increase. To improve the recycling rate of air conditioners the best solution is to make

horizontal requirements of product families so products that are recycled together consist

of compatible materials. Another solution is to improve the recycling facilities by investing

in improved sorting technologies or new technologies such as carbon capture

technologies 11 . Carbon capture technologies can in the future use CO2 (e.g. from

combustion of plastic) as a feedstock for polymers.

Opportunities for setting material efficiency requirements in ecodesign exist, however

without the appropriate assessment tool the impacts of any requirements cannot be

properly assessed. EcoReport tool can assess the impacts of the amount of raw materials

used, the percentage of mass fraction at end of life is reused, recycled or utilised for heat

recovery. Nevertheless, the EcoReport tool focuses mainly on energy and CO2-related

indicators, with the significant use phase energy consumption, any impacts of potential

material efficiency requirement are in comparison very small, in Task 5 it was also

concluded that the use phase related to the highest impacts due to the high energy

consumption. In addition, the environmental impacts of improving material efficiency

cannot be properly assessed as it is expected to have greater influence on other

environmental indicators not included in EcoReport Tool such as abiotic depletion.

Industry stakeholder implied that material efficiency requirements would have very little

impact as air conditioners are assembled and designed with repair and maintenance in

mind, and unlikely to affect the recycling process for air conditioners, as most of the

household appliances are shredded. In the sensitivity analyses in section 7.4, the potential

impacts of increasing the recycling rate to maximum are calculated and the results shows

little significance.

11 https://setis.ec.europa.eu/setis-reports/setis-magazine/carbon-capture-utilisation-and-storage/co2-feedstock-polymers

21

Table 5: Discussion on material efficiency improvements options presented in Task 4.

Difficulties Ecodesign opportunities

Current situation12

Many consumer products are facing reduction in their useful life. This means an increased resource consumption for production of new materials.

Requirements of availability of spare parts (selected parts)

Consulted European manufactures are providing spare parts as a service in the range of 7-12 year which seems reasonable as inefficient/old air conditioners should be replaced at some point. Though, this may not be always true for the lower end of the

market.

To avoid premature disposal of efficient air conditioners the cost of repair should be reduced so more air conditioners are repaired.

This will minimise the resource consumption of raw materials.

Requirements of exploded views13 and instructions for disassembly

Exploded views are already available from the largest manufacturers for repair (not for disassembly as the products are shredded14 anyways). Stakeholders have suggested that manufactures have a genuine interest in

informing the professional installers about the detailed design of each product to make the repair as easy as possible. It seems reasonable not to provide these information for regular customers due to safety risks (inappropriate disassemble and repair).

End-of-Life the products are most likely shredded and instructions for disassembly would be redundant for recyclers but may prove useful for reparation and refurbishment of appliances15.

Regarding repair and recycling efficiency it is

beneficial if certain components are easy to repair or remove End-of-Life. Especially PCBs are of

interest regarding repair (among the most sold spare parts) and End-of-Life treatment (critical raw materials).

Requirements regarding the number

of operation to remove targeted components (e.g. printed circuit boards

greater than 10 square centimetres)

Consulted European manufacturers have stated that most air conditioners already are

designed for fast and easy access and exchange of parts for repair, therefore they assumed that recyclers easily can remove the PCBs before shredding if desired.

Most refrigerants today have an GWP above 2000 and pose a serious threat to the environment.

Requirements of pump-down systems to minimise leakage of refrigerants End-of-Life

According to stakeholders the pump-down function is only useful if the End-of-Life at the site is planned. If the End-of-Life is caused by malfunctions the installer would anyways recover the refrigerant. Furthermore, the amount of leakage during decommissioning is

difficult to quantify and the F-gas regulation

will limit the impact. In addition, it is assumed that most air conditioners are equipped with a pump down function.

However, if material efficiency requirements are aligned across several regulations as

mentioned above, the impact may be much greater and it ensures regulatory consistency

within ecodesign framework. In Table 6, different material efficiency requirements in other

regulations are presented.

12 Based on inputs from EPEE 13 A technical drawing of the appliance showing position of each components inside 14 Currently, due to economic constraints most household appliances are shredded at recyclers and then e.g. the printed circuit boards are removed by eddy-current separation of sink/float separation. 15 Confirmed by former operator on AVERHOFF, Tom Ellegaard

22

Table 6: Alignment with other regulations 1.

Information requirements for refrigeration gases

2. Requirements for dismantling for the purpose of avoiding pollution, and for material recovery and recycling

3. Spare part availability

4. Spare part maximum delivery time

5. Access to repair and maintenance information

Dishwashers (Not yet adopted)

x x x x x

Washing machines (Not yet adopted)

x x x x x

Domestic refrigerators and freezers (Not yet adopted)

x x

Water Heaters x

Domestic and commercial ovens, hobs and grills

x

Residential Ventilation

x

Circulators and pumps

x

Ventilation Fans x

Electric motors x

Vacuum cleaners x

Local room heating products

x

Domestic and commercial ovens, hobs and grills

x

TVs x

Personal computers and portable computers

x

Dishwashers and washing machines may have the most ambitious requirements regarding

resource efficiency and requirements that support the circular economy. These regulations

are not yet adopted but they received general support16. Previously there have been

different requirements regarding information relevant for the disassembly, but one of the

greatest barriers towards increased repair and refurbishment is the lack of available spare

parts17. Though these requirements are difficult to quantify with the current methodology,

a study from Deloitte18 suggest that the following options might have a positive effect on

the environment:

• Measures to ensure provision of information to consumers on possibilities to repair

the product (corresponds to requirement 5 in Table 6)

• Measures to ensure provision of technical information to facilitate repair to

professionals (corresponds to requirement 1, 2 and 5 in Table 6)

• Measures to enable an easier dismantling of products (corresponds to requirement

2 in Table 6)

16 Industry stakeholders did not strongly oppose resource efficiency requirements, however

proposed change of wording in the current formulation of a few requirements, stakeholder comments 2017. 17 Deloitte (2016) Study on Socioeconomic impacts of increased reparability – Final Report. Prepared for the European Commission, DG ENV. 18 Deloitte (2016) Study on Socioeconomic impacts of increased reparability – Final Report. Prepared for the European Commission, DG ENV.

23

• Measures to ensure availability of spare parts for at least a certain amount of years

from the time that production ceases of the specific models (corresponds to

requirement 3 and 4 in Table 6)

• Different combination of the above-mentioned options

It is therefore recommended to consider aligning with material efficiency requirements

regulations for dishwashers, washing machines or domestic refrigerators and freezers.

7.1.5 Metrics changes

Impact of infiltration for single duct and double duct air conditioners

A mandate to CEN should be delivered to develop a test procedure to measure infiltration

air flow (i.e. condenser air flow when the unit is operated in cooling mode) for single duct

air conditioner. Different methods may be possible; for each of them, uncertainties for

these different methods need to be characterized.

7.1.5.1 Portable air conditioners: change in standard rated conditions in cooling

mode

To account for infiltration impact on performances, it is necessary to measure single duct

unit capacity and efficiency at test condition 27 °C indoor (wet bulb 19°C) / 27 °C outdoor

(wet bulb 19°C). This point should be used to define the rated capacity instead of 35 (24)

/ 35 (24).

For portable double duct units, a supplementary test point, that defines the product rated

capacity, is to be done at 27 °C (and 19 °C wet bulb temperature) outdoor inlet air

temperature / 27 °C (and 19 °C wet bulb temperature) indoor air inlet conditions.

7.1.5.2 Portable air conditioners: cooling mode metrics

To account for infiltration impact on cooling capacity and performance, the following air

flow (AF) should be considered for single duct in absence of test to measure the infiltration

air flow: 200 m3/h/kW rated cooling capacity

To compute seasonal efficiency in cooling mode:

𝑆𝐸𝐸𝑅 = 𝑄𝑐𝑒

𝑄𝑐𝑒 𝑆𝐸𝐸𝑅𝑜𝑛

+ 𝐻𝑇𝑂 × 𝑃𝑇𝑂 + 𝐻𝑆𝐵 × 𝑃𝑆𝐵

with

𝑄𝑐𝑒 = 10/24 × ∑ ℎ𝑗 × 𝑃𝑐_𝑐𝑜𝑟𝑟(𝑇𝑗)

𝑛

1

and

𝑆𝐸𝐸𝑅𝑜𝑛 =∑ ℎ𝑗 × 𝑃𝑐_𝑐𝑜𝑟𝑟(𝑇𝑗)𝑛

𝑗=1

∑ ℎ𝑗 × (𝑃𝑐_𝑐𝑜𝑟𝑟(𝑇𝑗)𝐸𝐸𝑅𝑏𝑖𝑛(𝑇𝑗)

)𝑛𝑗=1

Where,

• Tj = the bin temperature

• j = the bin number

24

• n = the amount of bins

• Qce: cooling energy supplied by the unit over a season

• SEER: the seasonal energy efficiency ratio in cooling mode

• SEERon: the seasonal energy efficiency ratio in cooling mode without accounting

standby and thermostat-off electricity consumption

• Pc_corr(Tj) = below equilibrium point: the cooling demand of the building for the

corresponding temperature Tj; above the equilibrium point: the capacity of the unit

for the corresponding temperature Tj

• hj = the number of bin hours occurring at the corresponding temperature Tj

• EERbin(Tj) = the EER values of the unit for the corresponding temperature Tj.

• HTO, HSB: the number of hours the unit is considered to work in thermostat-off mode

• PTO, PSB: the electricity consumption during thermostat-off mode

Calculation of Pc_corr(Tj) and EERbin(Tj) for single duct air conditioners

The rated capacity Qc(Tj) for temperature of bin j should be computed as follows.

𝑄𝑐(𝑇𝑗) = 𝑄𝑐(27) (𝐸𝑞 1)

Where:

• Qc(27): rated capacity at 27(19) indoor and outdoor

Capacity should then be corrected for infiltration as follows:

𝑄𝑐_𝑐𝑜𝑟𝑟(𝑇𝑗) = 𝑄𝑐(𝑇𝑗) + 𝑄𝐼𝑁𝐹(𝑇𝑗) (𝐸𝑞 2)

Where:

• Qc_corr(Tj): maximum capacity of the unit corrected with infiltration

• Qc(Tj): maximum capacity in bin Tj without accounting for infiltration

The infiltration impact is calculated with the following formulas:

𝐼𝑓 𝑇𝑗 < 27, 𝑄𝐼𝑁𝐹(𝑇𝑗) = 27 − 𝑇𝑗

27 − 20 × [𝐴𝐹 × (𝑟ℎ𝑜𝑎𝑖𝑟27

× ℎ27 − 𝑟ℎ𝑜𝑎𝑖𝑟20× ℎ20)]

𝐼𝑓 𝑇𝑗 > 27, 𝑄𝐼𝑁𝐹(𝑇𝑗) = 27 − 𝑇𝑗

35 − 27 × [𝐴𝐹 × (𝑟ℎ𝑜𝑎𝑖𝑟35

× ℎ35 − 𝑟ℎ𝑜𝑎𝑖𝑟27× ℎ27)] =

27 − 𝑇𝑗

35 − 27 × 𝐼𝑁𝐹

Where:

• 𝑄𝐼𝑁𝐹

(𝑇𝑗) : Heat loss by infiltration (W)

• Tj: outdoor temperature of bin j

• AF: infiltration air flow (m3/s)

• 𝑟ℎ𝑜𝑎𝑖𝑟20= 1.20 kg / m3, density of dry air at 20 °C (1 atm)



• ℎ20 = 42.2 kJ/kgda specific enthalpy of infiltration air at 20 °C dry bulb and 15 °C

wet bulb temperature per kg of dry air



25



• INF = infiltration in kW (cooling capacity loss - negative capacity value due to

infiltration)

Equilibrium temperature, which is the intersection between building load curve (Eq 3) and

capacity corrected with infiltration (Eq 2) is determined and noted Teq.

𝑄𝑐_𝑐𝑜𝑟𝑟(𝑇𝑗) = 𝑄𝑐(27) + 27 − 𝑇𝑗

35 − 27 × 𝐼𝑁𝐹 (𝐸𝑞 2)

𝐵𝐿(𝑇𝑗) = 𝑄𝑐(27) × (𝑇𝑗 − 23) / (35 − 23) (𝐸𝑞 3)

𝑇𝑒𝑞 =

𝑄𝑐(27) +27

35 − 27× 𝐼𝑁𝐹 +

23(35 − 23)

× 𝑄𝑐(27)

𝑄𝑐(27)35 − 23

+𝐼𝑁𝐹

(35 − 27)

(𝐸𝑞 4)

Pc_corr(Tj) is then computed as follows:

𝐼𝑓 𝑇𝑗 ≤ 𝑇𝑒𝑞: 𝑃𝑐_𝑐𝑜𝑟𝑟(𝑇𝑗) = 𝐵𝐿(𝑇𝑗)

𝐼𝑓 𝑇𝑗 > 𝑇𝑒𝑞: 𝑃𝑐_𝑐𝑜𝑟𝑟(𝑇𝑗) = 𝑄𝑐_𝑐𝑜𝑟𝑟(𝑇𝑗)

To compute EERbin(Tj), two cases may occur. In both cases, the capacity ratio should be

computed as follows:

𝐶𝑅(𝑇𝑗) = 𝑚𝑖𝑛 (1 ; 𝑃𝑐_𝑐𝑜𝑟𝑟(𝑇𝑗) / 𝐵𝐿(𝑇𝑗))

Case 1: on-off unit

𝐼𝑓 𝐶𝑅(𝑇𝑗) < 1; 𝐸𝐸𝑅𝑏𝑖𝑛(𝑇𝑗) = 𝐸𝐸𝑅𝑟𝑎𝑡𝑒𝑑 𝑥 (1 − 𝐶𝑑𝑐 𝑥 (1 − 𝐶𝑅(𝑇𝑗)))

With Cdc cycling coefficient with a value 0.25 by default.

Case 2: inverter unit

A supplementary test should be made at 27 (19) / 27 (19) temperature conditions and at

33 % capacity ratio. The part load coefficient of EER variation noted PLc should be


𝑃𝐿𝑐 =

𝐸𝐸𝑅(27; 33%) − 𝐸𝐸𝑅(27; 100%)𝐸𝐸𝑅(27; 100%)

𝑄𝑐(27; 100%) − 𝑄𝑐(27; 33%)𝑄𝑐(27; 100%)

(Eq 5)

And EERbin(Tj) should be computed as follows:

𝐼𝑓 𝐶𝑅(𝑇𝑗) ≥ 0.33; 𝐸𝐸𝑅𝑏𝑖𝑛(𝑇𝑗) = 𝐸𝐸𝑅𝑟𝑎𝑡𝑒𝑑 𝑥 (1 + 𝑃𝐿𝑐 𝑥 (1 – 𝐶𝑅(𝑇𝑗)))

𝐼𝑓 𝐶𝑅(𝑇𝑗) < 0.33; 𝐸𝐸𝑅𝑏𝑖𝑛(𝑇𝑗) = 𝐸𝐸𝑅𝑟𝑎𝑡𝑒𝑑 𝑥 (1 + 𝑃𝐿𝑐 𝑥 (1 – 0.33))𝑥(1 − 0.25 𝑥 (1 – 𝐶𝑅(𝑇𝑗)/0.33))

Calculation of Pc_corr(Tj) and EERbin(Tj) for double duct air conditioners

26

𝑄𝑐(𝑇𝑗) = 𝑄𝑐(27) + (𝑄𝑐(35) − 𝑄𝑐(27))/8 𝑥 (𝑇𝑗 – 27) (𝐸𝑞 1𝑏𝑖𝑠)

Where:

• Qc(27): rated capacity at 27(19) indoor and outdoor

• Qc(35): rated capacity at 27(19) indoor and 35(24) outdoor

Capacity should then be corrected for infiltration as follows:

𝑄𝑐_𝑐𝑜𝑟𝑟(𝑇𝑗) = 𝑄𝑐(𝑇𝑗) (𝐸𝑞 2𝑏𝑖𝑠)

Equilibrium temperature, which is the intersection between building load curve (Eq 3) and

capacity corrected with infiltration (Eq 2) is determined and noted Teq.

𝑄𝑐_𝑐𝑜𝑟𝑟(𝑇𝑗) = 𝑄𝑐(27) + (𝑄𝑐(35) − 𝑄𝑐(27))/8 𝑥 (𝑇𝑗 − 27) (𝐸𝑞 2𝑏𝑖𝑠)

𝐵𝐿(𝑇𝑗) = 𝑄𝑐(27) × (𝑇𝑗 − 23) / (35 − 23) (𝐸𝑞 3)

𝑇𝑒𝑞 = 𝑄𝑐(27) − 27 ×

𝑄𝑐(35) − 𝑄𝑐(27)8

+ 23 ×𝑄𝑐(27)

(35 − 23)

𝑄𝑐(27)35 − 23

−𝑄𝑐(35) − 𝑄𝑐(27)

(35 − 27)

(𝐸𝑞 4)

Pc_corr(Tj) is then computed as follows:

𝐼𝑓 𝑇𝑗 ≤ 𝑇𝑒𝑞: 𝑃𝑐_𝑐𝑜𝑟𝑟(𝑇𝑗) = 𝐵𝐿(𝑇𝑗)

𝐼𝑓 𝑇𝑗 > 𝑇𝑒𝑞: 𝑃𝑐_𝑐𝑜𝑟𝑟(𝑇𝑗) = 𝑄𝑐_𝑐𝑜𝑟𝑟(𝑇𝑗)

To compute EERbin(Tj), two cases may occur. In both cases, the capacity ratio (CR(Tj))

should be computed as follows:

𝐶𝑅(𝑇𝑗) = 𝑚𝑖𝑛 (1 ; 𝑃𝑐_𝑐𝑜𝑟𝑟(𝑇𝑗) / 𝐵𝐿(𝑇𝑗))

For double duct units, the efficiency at maximum capacity should be computed as follows:

𝐸𝐸𝑅(𝑇𝑗) = 𝐸𝐸𝑅(27) + (𝐸𝐸𝑅(35) − 𝐸𝐸𝑅(27))/8 𝑥 (𝑇𝑗 − 27)

Where:

• EER(27): rated EER at 27(19) indoor and outdoor

• EER(35): rated EER at 27(19) indoor and 35(24) outdoor

Case 1: on-off unit

𝐼𝑓 𝐶𝑅(𝑇𝑗) < 1; 𝐸𝐸𝑅𝑏𝑖𝑛(𝑇𝑗) = 𝐸𝐸𝑅(𝑇𝑗) 𝑥 (1 − 𝐶𝑑𝑐 𝑥 (1 − 𝐶𝑅(𝑇𝑗)))

With Cdc cycling coefficient with a value 0.25 by default.

Case 2: inverter unit

27

A supplementary test should be made at 27 (19) / 27 (19) temperature conditions and at

33 % capacity ratio. The part load coefficient of EER variation noted PLc should be


𝑃𝐿𝑐 =

𝐸𝐸𝑅(27; 33%) − 𝐸𝐸𝑅(27; 100%)𝐸𝐸𝑅(27; 100%)

𝑄𝑐(27; 100%) − 𝑄𝑐(27; 33%)𝑄𝑐((27; 100%)

(𝐸𝑞 5)

And EERbin(Tj) should be computed as follows:

𝐼𝑓 𝐶𝑅(𝑇𝑗) ≥ 0.33; 𝐸𝐸𝑅𝑏𝑖𝑛(𝑇𝑗) = 𝐸𝐸𝑅𝑟𝑎𝑡𝑒𝑑 𝑥 (1 + 𝑃𝐿𝑐 𝑥 (1 – 𝐶𝑅(𝑇𝑗)))

𝐼𝑓 𝐶𝑅(𝑇𝑗) < 0.33; 𝐸𝐸𝑅𝑏𝑖𝑛(𝑇𝑗) = 𝐸𝐸𝑅𝑟𝑎𝑡𝑒𝑑 𝑥 (1 + 𝑃𝐿𝑐 𝑥 (1 – 0.33))𝑥(1 − 0.25 𝑥 (1 – 𝐶𝑅(𝑇𝑗)/0.33))

7.1.5.3 Metrics change for double duct products (fix and portable) in heating mode

The intent is to use the same methodology for double duct as for split air conditioners in

heating mode following EN14825 standard. There is in fact no difference to be made as

infiltrations are already included in the tests done for double duct units.

Because of the effect of infiltration, bivalent temperature points should be set higher than

for products without infiltration. Bivalent temperatures used in Regulation EU no 206/2012

can be used for double duct heat pumps.

Changes in metrics for fixed air conditioners and heat pumps

Crankcase hours should be adjusted.

7.1.6 Proposed tolerances and uncertainties

Present tolerance levels in Regulation (EU) No 206/2012

Tolerances are defined as follows:

• EER of single duct and double duct appliances: 10 %

• SEER and SCOP of split air conditioners: 8 %

Tolerance and uncertainty: background

Fixing tolerance is a political decision. CEN/CENELEC Eco-design Coordination Group19

defines the general policy for Ecodesign measures on how to choose appropriate tolerance

levels. This should be based upon the expanded measurement uncertainty which includes

the repeatability and reproducibility components. Repeatability refers to measurement

uncertainty of the same unit tested several times in the same laboratory. Reproducibility

refers to variations between laboratories. This leaves to manufacturers the charge of the

variations due to manufacturing.

Expanded measurement uncertainties should be based upon the results of Round Robin

tests (RRT), if available. According to CEN/CENELEC Eco-design Coordination Group, "the

expanded uncertainty is taken as the product of (a) a coverage factor (usually equal to

2) that yields an interval of values within which the true value lies with a level of

19 http://ecostandard.org/wp-content/uploads/ECO-CGN0195-Recommendations-for-establishing-verification-tolerance-considering-measurement-uncertainty.pdf

28

confidence of approximately 95 %, and (b) the standard deviation of the results divided

by the square root of the number of results".

It is thus strongly advised to lead Round Robin tests for both SEER of portable air

conditioners and SEER and SCOP of fixed air conditioners. However, at the time this report

is written, such results are not available. For portable air conditioners, a preliminary report

on a still on-going Round Robin test reported by UBA 20 could allow to compute EER

expanded uncertainties: reproducibility standard deviation was determined to be of 1 %

(test in 2 different laboratories) and the repeatability standard deviation was not greater

than 0.6 % in each test laboratory (with 4 tests by laboratory). Further results from

additional laboratories are expected by mid-2018 to deliver statistically valid reproducibility

value. Applying Eco-design coordination group methodology to present results (an

approximation is used here as individual test results have not been supplied) would lead

to expanded uncertainties below 3 % (2 x √(0.012+0.0062) = 2.3 %). This seems very low

as compared to present tolerances of 10 % on EER for single duct air conditioners in

Regulation (EU) n° 206/2012 so it seems better to wait for the complete RRT to be

completed and final report to become available.

In absence of Round Robin test indications, existing standard EN14825:2016 includes

maximum measurement expanded uncertainties (including both repeatability and

reproducibility) for capacity and electricity values so that it is possible to calculate

maximum expanded measurement uncertainty for seasonal performance indicators. These

expanded measurement uncertainties are also used for portable air conditioners here

because the same measurement method as for split air conditioners (calorimetric room) is

also used for these products. A supplementary measurement is required for single duct air

conditioners, this is the condenser air flow, which measurement expanded uncertainty is 5

% according to EN14511-3:2013.

To calculate the expanded uncertainty, as measurement uncertainties indicated in

EN14825:2016 are expanded measurement uncertainties, it is enough to propagate the

uncertainties to compute seasonal performance metrics expanded uncertainties of

measurement from these values.

We then use this method to determine the maximum expanded uncertainties from available

standard information for a number of representative units. Calculation of SEER and SCOP

uncertainties are done using the software EES21, which allows to prevent uncertainty

propagation uprate due to derivative calculation simplifications or errors. Discussion with

test laboratories on this subject show there might be a need for a CEN TC 113 guidance

on how to calculate measurement uncertainties for SEER / SCOP as the calculation by hand

is quite complex and time consuming (and then may lead to significant errors).

Individual measurement uncertainties

Expanded individual measurement uncertainties are defined as:

• (EN14825:2016) Regarding thermal capacities: 15 % below 1 kW, 10% between 1

and 2 kW, 5 % above 2 kW and 10 % (or 15 % if capacity is less than 1 kW) in

non-stationary conditions - i.e. for test points including frost/defrost cycles.

20 UBA and BAM, Comments received February 6 2018. 21 Klein, S.A., EES – Engineering Equation Solver, Version 10.039, 2016, F-Chart Software, http://fchart.com

29

• (EN14825:2016) Regarding electric power: 1 % with a minimum value of 0.1 W

below 10 W (useful for auxiliary power mode measurement22)

• (EN14511:3, 2016) For infiltration measurement of single duct air conditioners, 5%

on the air flow rate.

Best possible values achievable by the time of the measures have been discussed with test

laboratories:

• Regarding thermal capacities: 10 % below 2 kW, 5 % above 2 kW and 5 % (or 10

% if capacity is less than 1 kW) in non-stationary conditions - i.e. for test points

including frost/defrost cycles.

• Regarding electric power: 1 % with a minimum value of 0.1 W below 10 W

• For infiltration air flow measurement of single duct air conditioners, 5%.

Note that for infiltration air flow of single duct air conditioners, manufacturers indicated

that the air flow test is to be done in realistic operating conditions because the air flow

decreases when the quantity of condensates increases in the condenser air flow (most

single duct units indeed recirculate the condensates from the evaporator to the condenser

so that they may be evaporated). The impact of a higher uncertainty level of 10 % is thus

tested hereafter.

EU test laboratories have indicated that to further decrease expanded measurement

uncertainties for thermal capacities, which are the major components in the final

repeatability uncertainty of SEER and SCOP value, it would be necessary that EU test

laboratories build new calorimetric room chambers of smaller size, which, even if they had

the money to invest in, could not be realistically ready at the time revised air conditioner

regulations enter into force. Basing upon the example of measurement uncertainty in other

economies, manufacturers believe it is still possible to go lower by forcing all test

laboratories to standardize some of the measurement methods between the laboratories.

Expanded uncertainty calculation for split air conditioners

Six different unit types are considered. For these units, all parameters required to compute

SEER / SCOP are available. For all these units, as explained before in Task 4, the building

load required at D point condition cannot be reached. This tends to reduce the

measurement uncertainty for lower capacity units as measurement uncertainties presently

increases with decreasing capacity. Consequently, it is supposed in what follows that the

same efficiency at D point can be obtained without cycling but by adjusting the capacity to

the required building load. This gives an idea of the uncertainty increase for machines that

can reach such low capacity levels. This tend to increase SEER/SCOP expanded uncertainty

between 0.5 % (smaller units) to 0.3 % (larger units).

Calculation results are shown in Table 7 for both present uncertainty levels and the

improved scenario described above.

22 Note this value is to be increased to 0.3 W in the next revision of EN14825:2016, but this has a negligible impact on SEER and SCOP uncertainty values.

30

Table 7: Measurement uncertainty calculation results for 6 split units of different sizes.

Expanded uncertainty

Products Cooling capacity (kW) SEER SCOP Unc_SEER % Unc_SCOP %

1.5 5.7 4.0 7.1% 8.4%

2.5 7.8 4.6 5.3% 6.5%

3.5 8.5 4.7 4.8% 5.8%

5 6.1 4.2 3.2% 5.9%

7 7.1 4.0 3.1% 5.8%

10.5 6.1 4.0 2.8% 5.8%

Expanded uncertainty

Products Cooling capacity (kW) SEER SCOP Unc_SEER % Unc_SCOP %

1.5 5.7 4.0 5.1% 5.6%

2.5 7.8 4.6 4.9% 5.7%

3.5 8.5 4.7 4.3% 5.6%

5 6.1 4.2 3.2% 3.6%

7 7.1 4.0 3.1% 3.6%

10.5 6.1 4.0 2.8% 3.0%

Tolerance in Regulations (EU) n°206/2012 and 626/2011 should be set close to the

expanded uncertainty levels. The 8 % tolerance in these regulations is compatible for all

units except in heating mode for less than 2 kW unit for which expanded measurement

uncertainty is 8.4 %. However, the D point capacity in real life cannot be reached and so

the expanded uncertainty is close to 8 %.

With present expanded measurement uncertainties in EN14825:2016, tolerance could

already be reduced for the higher capacity range. In the present situation, the following

maximum expanded uncertainties could be used to set tolerances as follows:

• SEER tolerance: 8 % below 2 kW cooling capacity, 6 % between 2 and 6 kW and 4 %

between 6 and 12 kW.

• SCOP tolerance: 8 % below 2 kW cooling capacity, 7 % between 2 and 6 kW and 6 %

between 6 and 12 kW.

With the improved accuracy in the second scenario, (expanded uncertainties and so)

tolerances could be reduced to 6 % below 6 kW cooling capacity and 4 % between 6 and

12 kW for both SEER and SCOP.

Expanded uncertainty calculation for portable air conditioners

For portable air conditioners, the base case single duct appliance is used, part load control

is either on/off cycling or with compressor inverter; in that later case, it is supposed the

test point capacity at 33 % can be reached by reducing the frequency (this maximize

capacity measurement uncertainty at low load). Two values regarding air flow

measurement uncertainties are considered given that the measurement methodology is

not yet fixed, 5 % and 10 %.

Calculation results are shown in Table 8 below.

31

Table 8: Measurement uncertainty calculation results for 2 single duct units of different sizes

Existing individual uncertainty

Products Cooling capacity

(kW)

Unc_Air

flow rate

%

SEER T_eq P[T_eq] Unc_SEER

%

Unc_Teq % Unc_P[T_eq]

%

2.44 kW (27) ON/OFF 5% 2.1 30.0 1.42 5.8% 0.4% 6.5%

2.44 kW (27) ON/OFF 10% 2.1 30.0 1.42 5.9% 0.7% 6.9%

2.44 kW (27) Inverter 5% 2.9 30.0 1.42 7.5% 0.4% 6.5%

2.44 kW (27) Inverter 10% 2.9 30.0 1.42 7.6% 0.7% 6.9%

1.90 kW (27) ON/OFF 5% 2.1 30.0 1.10 11.3% 0.7% 12.7%

1.90 kW (27) ON/OFF 10% 2.1 30.0 1.10 11.4% 0.9% 13.0%

1.90 kW (27) Inverter 5% 2.9 30.0 1.10 10.0% 0.7% 12.7%

1.90 kW (27) Inverter 10% 2.9 30.0 1.10 10.1% 0.9% 13.0%

With reduced individual uncertainties - Repeatability only

Products Cooling capacity

(kW)

Unc_Air

flow rate

%

SEER T_eq P[T_eq] Unc_SEER

%

Unc_Teq % Unc_P[T_eq]

%

2.44 kW (27) ON/OFF 5% 2.1 30.0 1.42 5.8% 0.4% 6.5%

2.44 kW (27) ON/OFF 10% 2.1 30.0 1.42 5.9% 0.7% 6.9%

2.44 kW (27) Inverter 5% 2.9 30.0 1.42 5.8% 0.4% 6.5%

2.44 kW (27) Inverter 10% 2.9 30.0 1.42 6.0% 0.7% 6.9%

1.90 kW (27) ON/OFF 5% 2.1 30.0 1.10 11.3% 0.7% 12.7%

1.90 kW (27) ON/OFF 10% 2.1 30.0 1.10 11.4% 0.9% 13.0%

1.90 kW (27) Inverter 5% 2.9 30.0 1.10 8.8% 0.7% 12.7%

1.90 kW (27) Inverter 10% 2.9 30.0 1.10 8.9% 0.9% 13.0%

Air flow measurement uncertainty has a very limited influence on the performance

parameters. Although no smaller than 2 kW (capacity @ 27/27) unit could be identified in

today EU market, if such a unit was available, tolerances should be much higher than for

higher than 2 kW units. If inverter units become available on the EU market, the

uncertainties and tolerances need to be higher.

In the present situation, the following maximum expanded uncertainties could be used to

set tolerances as follows:

o SEER: 6 % for on/off and 8 % for inverter (12 % for lower than 2 kW @ 27/27

units)

o Pc(Teq): 7 % (13 % for lower than 2 kW @ 27/27 units)

o Teq: 0.3 K (0.4 K for lower than 2 kW @ 27/27 units)

The improved accuracy scenario would allow to lower the SEER uncertainty as follows:

o SEER: 6 % (12 % for lower than 2 kW @ 27/27 units)

Conclusion: proposal regarding tolerances of performance parameters

According to previous definitions, tolerances should be higher than the repeatability

measurement uncertainty alone and lower or equal to the expanded uncertainty. In

absence of RRT, tolerance values should be fixed to the maximum possible value, i.e. to

the level of the maximum expanded uncertainties.

32

With present measurement uncertainties, tolerance levels can be set as follows:

• split air conditioners:

o SEER tolerance: 8 % below 2 kW cooling capacity, 6 % between 2 and 6 kW

and 4 % between 6 and 12 kW.

o SCOP tolerance: 8 % below 2 kW cooling capacity, 7 % between 2 and 6 kW


• portable air conditioners:


units)



SEER and SCOP tolerance levels in Regulations (EU) No 206/2012 and 626/2011 need to

be revised.

With improved measurement accuracy, tolerances could be reduced to the following levels:


o SEER: 6 % below 6 kW cooling capacity and 4 % between 6 and 12 kW

o SCOP: 6 % below 6 kW cooling capacity and 4 % between 6 and 12 kW



Further discussions with test laboratories and manufacturers are required about the

conditions of feasibility and timing of this improved scenario.

These proposed air conditioner performance indicators should be the subject of regular

Round Robin Tests amongst EU laboratories. These RRT should be used to calculate the

expanded measurement uncertainties from test results and to lower tolerances depending

on the RRT results. Individual measurement uncertainties on capacity should also be

adjusted depending on the results of such campaigns.

A RRT campaign is on-going for portable air conditioners and could be used to reduce the

expanded uncertainty on EER measurements and thus also on the performance parameters

indicated here.

7.2 Scenario analysis

The scenario analysis investigates the impact of the current regulation and revised

regulation regarding reduction in energy consumption and emission of CO2-eq. The impact

of changes to material composition are not included as the impacts are very limited due to

changes in the material composition. Nor are suggestions towards improved material

efficiency included due to the limited impact (industry have already improved due to a

focus on reparability) and to the difficulties with quantifying the improvement potential.

33

The options investigated are all related to improved energy efficiency and sound power

level. The investigated options are:

• Option 0 and 1: BAU scenario (before and after current regulation)

• Option 2: Revised Ecodesign requirement

• Option 3: Revised Energy labelling

• Option 4: Combination of revised Ecodesign and Energy labelling

These options are all modelled according to the assumed effect on the proposed

requirements and are used to model different scenarios. These scenarios are dependent

on the different potential improvement options presented in Task 6. The modelled

scenarios and the correlation with the improvement options presented in Task 6 are shortly

described in the table below.

Table 9: Summary of policy scenarios and brief descriptions

Policy

scenario

Description

Scenario 0

(0 BAU)

BAU before EU regulation – In general low yearly improvements. The

only improvement included is the use of inverter technology

Scenario 1

(1 BAU)

BAU scenario (current regulation) – The impact of the current regulation

with only limited incentive to improve products beyond the A+++ label

Scenario 2

(1 tier eco)

Ecodesign minimum efficiency requirement with one tier based on LLCC

(BC 1 for BC 1, -10%Ua_cond for BC 2 and HE1with R290for BC 3)

Scenario 3

(lbl)

Energy class A as BNAT (combining the different improvement for each

of the base cases)

Scenario 4

(eco+lbl)

Ecodesign and Energy labelling scenario 2 + scenario 3

The impacts of the different scenarios are calculated based on the stock and the annual

sales. Furthermore, all scenarios are built on different assumptions from Task 5 and Task

6 and are presented in Annex 1.

The development of SEER and SCOP in the different scenarios are presented below in the

different scenarios.

7.2.1 Before EU regulation – 0 scenario

The before EU regulation scenario is used as a baseline to show how effective the EU

intervention has been so far. Though, this is difficult since the regulation in countries

outside of the EU also have an effect on the European market. The assumptions made to

model the improvements on SEER and SCOP are mainly focusing on the shift to inverter

technology which supposedly also would have happened without any intervention from EU.

The assumed average SEER and SCOP development for air conditioners sold are presented

in Table 10.

Table 10: Development of SEER and SCOP of air conditioners sold - with no EU regulation

1995 2000 2005 2010 2015 2020 2025 2030 2035 2040

SEER

BC1 2.18 2.30 2.76 3.22 3.68 4.14 4.59 5.05 5.51 5.65

BC2 1.88 1.99 2.41 2.84 3.26 3.68 4.11 4.53 4.95 5.08

BC3 1.22 1.28 1.34 1.39 1.44 1.50 1.55 1.60 1.66 1.68 SCOP

BC1 1.85 1.93 2.21 2.48 2.76 3.03 3.31 3.58 3.86 3.96

BC2 1.60 1.67 1.93 2.18 2.44 2.70 2.95 3.21 3.47 3.56

BC3 - - - - - - - - - -

34

Without the EU regulation the SEER and SCOP levels in 2040 are not even on par with the

current situation in 2017. So, the regulation has accelerated the development significantly.

The energy and emission of CO2 are calculated based on these values in Table 11. Note

that the hours in heating mode and cooling mode are the same in all scenarios to make

the impacts in the different scenarios comparable.

Table 11: The annual energy consumption and emission of CO2-eq in scenario 0 (no intervention from EU)

1995 2000 2005 2010 2015 2020 2025 2030 2035 2040

Electricity consumption (TWh)

BC1 4.5 13.2 26.7 37.9 38.7 36.4 42.6 52.2 62.7 75.3

BC2 2.4 6.7 12.8 19.6 22.7 22.4 25.3 29.3 33.7 38.7

BC3 0.4 0.9 1.1 1.2 1.1 1.0 1.0 1.0 1.0 1.0

Total 7.3 20.8 40.6 58.6 62.6 59.8 69.0 82.6 97.4 115.0 mt CO2-eq

BC1 2.6 6.6 12.9 17.4 17.6 16.5 18.7 22.2 26.3 31.5

BC2 1.3 3.3 6.2 9.0 10.4 10.2 11.2 12.5 14.2 16.2

BC3 0.2 0.4 0.5 0.6 0.6 0.5 0.5 0.5 0.5 0.5

Total 4.1 10.3 19.7 27.1 28.6 27.2 30.4 35.2 40.9 48.2

Sound power level

Before the regulation the sound power level varied a lot for the different air conditioners

from quieter to more noisy air conditioners than today. It should be noted that it is difficult

to link air flow and sound power level. Though, air flow is clearly one of the main factors

in determining the sound power levels, and it is challenging to increase efficiency while

reducing sound power level further. The sound power level of air conditioners is presented

in Figure 5 and Figure 6.

Figure 5: ECC directory 2006, air conditioners below 12 kW, sound power level of indoor unit in cooling mode

30

35

40

45

50

55

60

65

70

75

80

0 2 4 6 8 10 12 14

A-w

eig

hte

d p

ow

er s

ou

nd

[d

B]

Cooiling Capacity [kW]

Sound Power Level Indoor

35

Figure 6: ECC directory 2006, air conditioners below 12 kW, sound power level of outdoor unit in cooling mode

These figures show the sound power level of air conditioners before the current EU

regulation.

7.2.2 Business-as-Usual (BAU) - scenario 1

The business-as-usual scenario quantifies the effect of the current regulation (Ecodesign

Regulation 206/2012 and Energy Labelling 626/2011) so far and estimate the development

until 2040. By comparing scenario 0 and scenario 1 it is possible to calculate the saved

energy and emission of CO2-eq due to the current regulation.

The SEER and SCOP values are based on the current development until today and with no

other enforcement for improvement it is estimated that BAT levels (from the preparatory

study) first will be reached in 2050. The assumed SEER, SCOP are presented in Table 12.

Table 12: Development of SEER and SCOP with the current regulation

1995 2000 2005 2010 2015 2020 2025 2030 2035 2040

SEER

BC1 2.18 2.44 3.63 4.81 6.00 6.36 6.71 7.07 7.43 7.79

BC2 1.88 2.15 3.37 4.58 5.80 6.01 6.23 6.44 6.66 6.87

BC3 1.22 1.31 1.48 1.65 1.83 1.87 1.91 1.96 2.00 2.05 SCOP

BC1 1.85 2.01 2.67 3.34 4.00 4.09 4.17 4.26 4.34 4.43

BC2 1.60 1.77 2.51 3.26 4.00 4.04 4.09 4.13 4.17 4.21

BC3 - - - - - - - - - -

Just by comparing the improvement in SEER and SCOP it is visible that the current

regulation has had a significant impact for fixed air conditioners. The improvements are

approximately 50 % for SEER and SCOP in 2020. This development in SCOP are properly

also one of the main reasons for the increased use of fixed air conditioners in heating

mode. Air conditioners are replacing inefficient electric radiators as the savings are

increasing due to the improved performance of air conditioners. The replacement of

inefficient heaters will lead to even larger savings which not are accounted in the presented

values below. The smallest increase in efficiency is for portable air conditioners. The SEER

has improved from 1.50 in scenario 0 to 1.87 in scenario 1 (2020).

40

45

50

55

60

65

70

75

80

85

0 2 4 6 8 10 12 14

A-w

eig

hte

d p

ow

er s

ou

nd

[d

B]

Cooiling Capacity [kW]

Sound Power Level Outdoor

36

The annual energy consumption and emission of CO2-eq of scenario 1 are calculated

compared to scenario 0 in the presented figures below.

Figure 7: Comparison of the annual energy consumption of scenario 0 and scenario 1.

Figure 8: Comparison of the annual emission of CO2-eq in scenario 0 and scenario 1.

It is visible that both the energy consumption and emission of CO2-eq have been reduced

significantly due to the current regulation. The annual savings of energy and CO2-emission

is approximately 20 TWh and 8 mt CO2-eq. In Table 13, the annual electricity consumption

and emission of CO2-eq for each of the base cases are presented and the annual saving

compared to scenario 0 (before regulation).

0

20

40

60

80

100

120

140

1990 2000 2010 2020 2030 2040

TWh

Scenario 0(0 BAU)

Scenario 1(1 BAU)

20 TWh

0

10

20

30

40

50

60

1990 2000 2010 2020 2030 2040

mt

CO

2 Scenario 0(0 BAU)

Scenario 1(1 BAU)

8 mt CO2-eq

37

Table 13: The annual energy consumption and emission of CO2-eq in scenario 1 (current regulation)

1995 2000 2005 2010 2015 2020 2025 2030 2035 2040


BC1 4.5 13.1 24.0 30.4 28.4 25.3 30.7 40.2 51.2 64.1

BC2 2.4 6.6 11.3 14.7 15.1 14.0 16.6 20.8 25.7 31.1

BC3 0.4 0.9 1.0 1.0 0.9 0.8 0.8 0.8 0.8 0.8

Total 7.3 20.6 36.3 46.2 44.5 40.2 48.1 61.8 77.7 96.0 mt CO2-eq

BC1 2.6 6.5 11.9 14.6 13.6 12.2 14.2 17.6 21.9 27.2

BC2 1.3 3.3 5.6 7.1 7.5 7.0 7.8 9.2 11.1 13.3

BC3 0.2 0.4 0.5 0.6 0.5 0.4 0.4 0.4 0.4 0.4

Total 4.1 10.2 18.0 22.3 21.6 19.6 22.4 27.2 33.4 40.9 Annual energy and mt CO2-eq savings compared with 0 BAU


BC1 0 0.10 2.71 7.42 10.32 11.04 11.89 12.04 11.48 11.24

BC2 0 0.06 1.58 4.88 7.60 8.35 8.78 8.56 8.04 7.64

BC3 0 0.00 0.04 0.12 0.18 0.20 0.21 0.19 0.18 0.18

Total 0 0.17 4.33 12.43 18.10 19.59 20.87 20.79 19.70 19.06 mt CO2-eq

BC1 0 0.04 1.04 2.85 3.96 4.24 4.57 4.62 4.41 4.32

BC2 0 0.02 0.61 1.88 2.92 3.21 3.37 3.29 3.09 2.94

BC3 0 0.00 0.02 0.05 0.07 0.08 0.08 0.07 0.07 0.07

Total 0 0.06 1.66 4.77 6.95 7.53 8.02 7.99 7.57 7.32

The majority of the saving are originating from small fixed air conditioners due to their

high improvements in SEER and SCOP and the large stock.

In the table below is the combined accumulated savings in energy and emission of CO2-eq

presented.

Table 14: The accumulated savings in energy and emission of CO2-eq in scenario 1 (effect of current regulation) compared to scenario 0

1995 2000 2005 2010 2015 2020 2025 2030 2035 2040

TWh 0 0 11 58 138 234 336 441 542 638 Mt CO2-eq

0 0 4 22 53 90 129 169 208 245

The current regulation has by 2015 saved more than 138 TWh electricity and avoided more

than 53 mt CO2-eq. These accumulated saving are only increasing in the future.

Scenario 1 are used as the current baseline in the policy scenarios.

Sound power level

The sound power level in 2016 shows the sound power levels of air conditioners after the

enforcement of the regulation, see figures below.

38

Figure 9: Comparison of the indoor sound power level in 2006 (blue dots and) and 2016 (Green dots)

Figure 10: Comparison of the outdoor sound power level in 2006 (blue dots and) and 2016 (Green dots)

It is visible that the current regulation has been effective since the noisiest air conditioners

are removed from the market. It is also visible that many air conditioners are close to the

current requirements and without sound power level requirements the air conditioners

would have had higher values. Today the average indoor sound power level of fixed split

air conditioners (≤6 kW) is 56.3 dB(A) while the average outdoor sound power level is 62.3

dB(A). For larger air conditioners (>6 kW) the average indoor sound power level is 61

dB(A) while the average outdoor sound power level is 67.6 dB(A).

As discussed in Task 6, there is little to none margin for sound power level improvement

while increasing energy efficiency of 0 – 6 kW capacity air conditioners as well as portable

air conditioners. Although there is slightly more room for improvement for 6 – 12 kW range,

it may require a more precise requirement of sound power level proportional to the

capacities.

39

7.2.3 Policy scenarios

The policy scenarios show the potential for future requirements. Other countries around

the world are also progressively strengthening their requirements and EU should not lag

behind in this positive development. Both USA and Japan have currently more ambitious

requirements that will benefit the environment.

Based on the LLCC and BAT technologies in Task 6 it is possible to determine a new set of

requirements and a new label scheme. These are presented in Table 2 and Table 3 above.

Based on the new requirements it is possible to model the future evolution on SEER and

SCOP. The predicted evolution is presented in the table below:

Figure 11: Comparison of the SEER development for BC1 in all scenarios

Figure 12: Comparison of the SEER development for B2 in all scenarios

2

3

4

5

6

7

8

9

10

2010 2015 2020 2025 2030 2035 2040 2045 2050

BC 1 - SEER

Scenario 0(0 BAU)

Scenario 1(1 BAU)

Scenario 2(1 tier eco)

Scenario 3(lbl)

Scenario 4(eco+lbl)

2

3

4

5

6

7

8

9

2010 2015 2020 2025 2030 2035 2040 2045 2050

BC 2 - SEER

Scenario 0(0 BAU)

Scenario 1(1 BAU)


Scenario 3(lbl)

Scenario 4(eco+lbl)

40

Figure 13: Comparison of the SEER development for BC3 in all scenarios

Figure 14: Comparison of the SCOP development for BC1 in all scenarios

1

2

3

4

5

2010 2015 2020 2025 2030 2035 2040 2045 2050

BC 3 - SEER

Scenario 0(0 BAU)

Scenario 1(1 BAU)


Scenario 3(lbl)

Scenario 4(eco+lbl)

2

3

4

5

6

2010 2015 2020 2025 2030 2035 2040 2045 2050

BC 1 - SCOP

Scenario 0(0 BAU)

Scenario 1(1 BAU)


Scenario 3(lbl)

Scenario 4(eco+lbl)

41

Figure 15: Comparison of the SCOP development for BC2 in all scenarios

From the figures it is visible that air conditioners still have the technological potential for

further improvement in efficiency for both heating and cooling. These assumptions are

based on the different improvement options in Task 6. With a new and stricter Ecodesign

requirements the development can be boosted in the coming years as less efficient

products are banned from the market. After this boost in efficiency the improvements are

assumed to flatten. If only the labelling scheme are adopted a steady improvement are

assumed until BNAT levels are reached in 2050.

Comparing the different base cases, it is visible that fixed air conditioners have the highest

improvement potential compared to scenario 1. Currently portable air conditioners have

not improved at the same pace as fixed air conditioners.

The annual energy consumption and emission of CO2-eq are calculated for all the scenarios

and presented figures below. All values are also presented in Table 33 to Table 37 in Annex

3 where the values per base cases are presented. Primary energy consumption is also

presented in these tables in Annex 3.

1

2

3

4

5

2010 2015 2020 2025 2030 2035 2040 2045 2050

BC 2 - SCOP

Scenario 0(0 BAU)

Scenario 1(1 BAU)


Scenario 3(lbl)

Scenario 4(eco+lbl)

42

Figure 16: Comparison of the annual energy consumption of three base cases in all scenarios

Figure 17: Comparison of the annual emission of CO2-eq of three base cases in all scenarios

From the figure it is visible that the annual saving is the highest for scenario 4a with annual

saving of 3.5 TWh and 1.4 mt CO2-eq in 2030 (compared to scenario 1). From the figures

it is not possible to see how the scenarios effect each of the base case. The annual savings

compared to scenario 1 (current regulation) for electricity, primary energy and emission of

CO2-eq for each of the base cases are presented in the tables below. In Annex 3 the annual

energy consumption for different policy scenarios are presented.

35

45

55

65

75

85

95

105

115

2015 2020 2025 2030 2035 2040

TWh

Scenario 0(0 BAU)

Scenario 1(1 BAU)


Scenario 3(lbl)

Scenario 4(eco+lbl)

15

20

25

30

35

40

45

50

55

2015 2020 2025 2030 2035 2040

mt

CO

2

Scenario 0(0 BAU)

Scenario 1(1 BAU)


Scenario 3(lbl)

Scenario 4(eco+lbl)

43

Table 15: Impacts of scenario 2 (1 tier eco) – Annual savings compared to scenario 1 (current

regulation) in TWh, Primary energy and CO2-eq

2010 2015 2020 2025 2030 2035 2040

Scenario 2 (1 tier eco)

TWh (Electricity)

BC1 0 0 0.16 0.99 2.00 2.67 3.31

BC2 0 0 0.05 0.29 0.60 0.81 1.01

BC3 0 0 0.01 0.09 0.14 0.15 0.14

Total 0 0 0.21 1.37 2.75 3.63 4.46

PJ (Primary energy)

BC1 0 0 1.40 8.88 18.04 24.02 29.77

BC2 0 0 0.41 2.65 5.41 7.29 9.11

BC3 0 0 0.12 0.79 1.30 1.31 1.30

Total 0 0 1.92 12.32 24.75 32.63 40.18

Mt CO2-eq

BC1 0 0 0.06 0.38 0.77 1.03 1.27

BC2 0 0 0.02 0.11 0.23 0.31 0.39

BC3 0 0 0.01 0.03 0.06 0.06 0.06

Total 0 0 0.08 0.53 1.06 1.39 1.72

Table 16: Impacts of scenario 3 (lbl) - Annual savings compared to scenario 1 (current regulation) in TWh, Primary energy and CO2-eq

2010 2015 2020 2025 2030 2035 2040

Scenario 3 (lbl)

TWh

(Electricity)

BC1 0 0 0 0.19 0.98 2.48 4.57

BC2 0 0 0 0.08 0.40 1.02 1.85

BC3 0 0 0 0.03 0.11 0.20 0.27

Total 0 0 0 0.30 1.49 3.70 6.69

PJ (Primary energy)

BC1 0 0 0 1.71 8.79 22.33 41.09

BC2 0 0 0 0.70 3.61 9.18 16.67

BC3 0 0 0 0.24 0.98 1.79 2.42

Total 0 0 0 2.66 13.39 33.30 60.18

Mt CO2-eq

BC1 0 0 0 0.07 0.38 0.95 1.75

BC2 0 0 0 0.03 0.15 0.39 0.71

BC3 0 0 0 0.01 0.04 0.08 0.10

Total 0 0 0 0.11 0.57 1.42 2.57

Table 17: Impacts of scenario 4 (eco+lbl) - Annual savings compared to scenario 1 (current regulation) in TWh, Primary energy and CO2-eq

2010 2015 2020 2025 2030 2035 2040

Scenario 4a (eco+lbl)

TWh (Electricity)

BC1 0 0 0.16 1.06 2.48 4.01 5.87

BC2 0 0 0.05 0.33 0.83 1.44 2.20

BC3 0 0 0.01 0.10 0.20 0.26 0.30

Total 0 0 0.21 1.48 3.51 5.70 8.38

PJ (Primary energy)

BC1 0 0 1.40 9.52 22.36 36.06 52.83

BC2 0 0 0.41 2.95 7.45 12.96 19.83

BC3 0 0 0.12 0.88 1.76 2.30 2.72

Total 0 0 1.92 13.34 31.57 51.32 75.38

Mt CO2-eq

BC1 0 0 0.06 0.41 0.95 1.54 2.26

BC2 0 0 0.02 0.13 0.32 0.55 0.85

BC3 0 0 0.01 0.04 0.08 0.10 0.12

Total 0 0 0.08 0.57 1.35 2.19 3.22

The highest savings are all connected with small air conditioners as they have higher

annual sales and because of their high improvement potential. For portable air conditioners

the savings are smaller.

The accumulated savings of the different policy options are compared to current regulation

(scenario 1) and presented in the figures below.

44

Figure 18: The accumulated savings in electricity (TWh) and emission of CO2-eq of the policy options compared to the current regulation (scenario 1)

Figure 19: The accumulated savings in emissions of CO2-eq of the policy options compared to the current regulation (scenario 1)

By applying both Ecodesign requirements and a new energy label scheme the accumulated

savings in 2040 are almost 80TWh and above 30 mt CO2-eq compared to scenario 1

(current regulation). Improving the current regulation will definitely have a positive and

significant impact on the environment.

7.3 Impact analysis for consumers and industry

7.3.1 Consumer impacts

The consumer impacts are related to the electricity consumption and the purchase price of

the equipment. The maintenance price and installation costs are assumed to be almost

unchanged from the different scenarios, so they are only calculated based on a fixed rate

and the annual sales.

0

10

20

30

40

50

60

70

80

2015 2020 2025 2030 2035 2040

TW

h

Scenario 2

(1 tier eco)

Scenario 3

(lbl)

Scenario 4(eco+lbl)

0

5

10

15

20

25

30

35

2015 2020 2025 2030 2035 2040

mt

CO

2-e

q

Scenario 2

(1 tier eco)

Scenario 3

(lbl)

Scenario 4

(eco+lbl)

45

The purchase price of the unit is dependent on the technological development in SEER, and

an annual product price decrease by 2 % which is according to MEErP23. The correlation

between SEER for the different base cases are calculated based on the different

improvement options presented in Task 6. In all options there seems to be a correlation

between SEER and then the product price. The correlation for the different base cases are:

• BC1 – 138 EUR/SEER point increase



This correlation and an annual price decrease are used to calculate the development in

purchase price. The assumed development in purchase price are calculated and presented

in Table 39 in Annex 3.

In most scenarios the price of air conditioners is expected to increase and especially the

most ambitious scenarios. The price increase is present in the scenarios including

Ecodesign requirements as the improvements are accelerated. In scenario 3 (only labelling

scheme) the annual cost reduction of 2 % exceeds the increase in price due to voluntary

efficiency improvements resulting in lower prices. The expected purchase price is used to

calculate the annual consumer expenditures in Figure 20. The annual consumer

expenditures are calculated based on the expected purchase price and expected annual

sales, see exact values for the base cases in Table 40 in Annex 3.

Figure 20: Annual consumer purchase costs of air conditioners in absolute values

The electricity price is expected to increase by 1 % per year. The assumed expected annual

energy consumption and the stock model is used for modelling the consumer expenditures

for the electricity presented in the Figure 21, see exact values of electricity costs for the

base cases in Table 41 in Annex 3.

23 VHK(2011), MEErP 2011 METHODOLOGY PART 1.

2.00

2.50

3.00

3.50

4.00

4.50

5.00

5.50

6.00

6.50

7.00

2015 2020 2025 2030 2035 2040

Bill

ion

EU

R

Scenario 0(0 BAU)

Scenario 1(1 BAU)

Scenario 2a(1 tier eco)

Scenario 3(lbl)

Scenario 4a(eco+lbl)

46

Figure 21: Annual consumer electricity costs in absolute values

The annual consumer expenditures for installation and maintenance are assumed negligible

and therefore are equal in all scenarios. For comparison with the other costs, the exact

installation and maintenance costs for each scenario are presented in Table 42 in Annex.

Total annual consumer expenditure is calculated as the sum of purchase cost, electricity

costs and annual installation and maintenance costs. The total annual consumer

expenditures are presented Figure 22 , and the annual consumer savings compared with

1 BAU current regulation in different policy options are presented in Table 18.

Figure 22: Total annual consumer expenditures in absolute values

7

9

11

13

15

17

19

21

23

2015 2020 2025 2030 2035 2040

Bill

ion

EU

R

Scenario 0(0 BAU)

Scenario 1(1 BAU)


Scenario 3(lbl)


13

15

17

19

21

23

25

27

29

31

33

2015 2020 2025 2030 2035 2040

Bill

ion

EU

R

Scenario 0(0 BAU)

Scenario 1(1 BAU)


Scenario 3(lbl)


47

Table 18: Total annual consumer expenditures in absolute values and annual savings compared

with 1 BAU current regulation

2010 2015 2020 2025 2030 2035 2040

Total annual consumer expenditures (billion EUR)

Scenario 0 (before regulation)

14.23 16.12 18.95 20.66 23.7 28.35 32.83

Scenario 1

(current regulation) 13.51 14.42 16.72 18.03 20.95 25.67 30.48


13.51 14.42 16.91 18.19 20.75 25.19 29.76

Scenario 3 (lbl)

13.51 14.42 16.72 18.09 20.91 25.31 29.68


13.51 14.42 16.91 18.25 20.83 25.15 29.51

Annual consumer expenditure saving compared with 1BAU


0 0 -0.18 -0.15 0.20 0.48 0.72

Scenario 3 (lbl)

0 0 0 -0.06 0.04 0.36 0.80


0 0 -0.18 -0.22 0.12 0.52 0.98

As the figures show that the annual consumer expenditures are similar in all policy options

but in the long term the scenarios with both Ecodesign requirements and labelling scheme

are the most advantageous for the consumers.

7.3.2 Industry impacts

The impacts for the industry are based on a number of assumptions from task 2 and from

MEErP. The assumptions are presented in the table below:

Table 19: Assumptions to model to industry impacts.

Impact Value Source

Fixed Manufacturer Selling Price as fraction of

Product Price [%] 45% From task 2 markup 2.2

Portable Manufacturer Selling Price as fraction of Product Price [%]

59% From task 2 markup 1.7

Margin Wholesaler [% on msp] 30% MEErP

Margin Retailer on product [% on wholesale price]

20% MEErP

Manufacturer turnover per employee [mln €/ a] 0.00035

Sector turnover 2109 mln euro / 6099

employed persons24

OEM personnel as fraction of manufacturer personnel [-]

1.2 MEErP

Wholesaler turnover per employee [mln €/ a]

0.00051

the entire wholesale sector turnover 5.3

trillion Euro10.4 million

employees25

Fraction of OEM personnel outside EU [% of OEM jobs]

80 %

24 Stakeholder input, January 2018 25 http://www.eurocommerce.eu/commerce-in-europe/facts-and-figures.aspx

48

The markups presented are average numbers covering both retail and wholesale. Portable

air conditioners (not installation), are mainly sold directly by retailers. Only about 5 % are

surely sold via installers according to BSRIA leading to a mark of 1.726.

For split air conditioners, the proportions of the different routes are more balanced, and

comparing with GfK total B2C sales, it can be assessed this share is larger than just the

retailer share in BSRIA statistics on first point of sales, higher than 40 %. According to

BSRIA it should also be lower than about 60 % (as installers and contractors represent

about 60 % of the total). Assuming a 50/50 sharing between final B2C retail and sales via

installers, this leads to a total markup of 2.227.

Based on these assumptions the industry impacts are calculated for the different scenarios

in the figures below.

Figure 23: Industry turnover per year for different policy scenarios

26 The markup value for portable air conditioners are explained and calculated in Task 2 27 The markup value for fixed air conditioners are explained and calculated in Task 2

1000

1500

2000

2500

3000

3500

4000

4500

2010 2015 2020 2025 2030 2035 2040

Turn

ove

r [m

ln €

/ a]

Scenario 0(0 BAU)

Scenario 1(1 BAU)


Scenario 2b(2 tiers eco)

Scenario 3(lbl)


49

Figure 24: Number of personnel in air conditioner industry for different policy scenarios

From the above figures it is also visible that the most ambitious options also are the most

beneficial for the manufactures as their turnover will increase and more workers will be

employed in the sector. The values presented in the above figures are also presented in

tables and divided into categories (manufacturer turnover, manufacture total personnel,

OEM total personnel, OEM total personnel (EU), wholesaler turnover and wholesaler total

personnel) in Annex 3 – Tables.

7.4 Sensitivity analysis

The sensitivity analysis is focusing on the leakage of refrigerant and the material

composition of the air conditioner. These analyses are made for scenario 5 as these factors

have a higher impact in this scenario due to the reduced energy consumption. Regarding

the sensitivity analysis the following adjustments are made:

• Sensitivity of the material composition

o 95 % recycling

• Sensitivity of the leakage of refrigerant

o Double the leakage rate

The impact of these changes is calculated as the difference in CO2-eq as this measure can

be used in both analyses.

Table 20: The calculated impacts of higher levels of recycling and the effect of higher leakage.

2010 2015 2020 2025 2030 2035 2040

Sensitivity (95% recycling) – Reduction in emission

Mt CO2-eq

BC1 0.10 0.09 0.11 0.16 0.33 0.69 1.19

BC2 0.06 0.06 0.07 0.09 0.18 0.34 0.57

BC3 0.02 0.01 0.01 0.02 0.03 0.05 0.07

Total 0.18 0.16 0.19 0.26 0.54 1.08 1.83

Sensitivity (Double leakage) – Increase in emission

Mt CO2-eq

BC1 2.92 2.84 2.34 1.92 1.44 1.29 1.47

BC2 1.47 1.64 1.44 1.17 0.83 0.71 0.78

BC3 0.05 0.05 0.04 0.02 0.00 0.00 0.00

Total 4.43 4.53 3.82 3.10 2.26 1.99 2.25

1000

1500

2000

2500

3000

3500

4000

4500

2010 2015 2020 2025 2030 2035 2040

Turn

ove

r [m

ln €

/ a]

Scenario 0(0 BAU)

Scenario 1(1 BAU)


Scenario 2b(2 tiers eco)

Scenario 3(lbl)


50

Note that in Table 20, for 95% recycling rate, the figures are the reduction in emission, for

double leakage rate, the figures are the increase in emission

The sensitivity analysis show that increased recycling can reduce the annual emission of

CO2-eq with approximately 0.2 mt, but the recycling rates in this scenario are very

optimistic and may not be obtainable in the near future. If the leakage is higher (e.g. twice

as high) than assumed, then the emission of CO2-eq be 3.8 mt higher in 2020. Due to the

f-gas regulation this impact is reduced to 2.3 mt CO2-eq in 2040 and the impact of leakage

is reduced. These tables are also presented in absolute values in Table 49 in Annex 3.

It is also proposed that sensitivity analysis to be carried out for product prices and

overcosts in the impact assessment.

7.5 Comparison of air-to-air heat pumps and other heating products

Air-to-air heat pump, despite being a specific product group and having presently its own

Ecodesign and Labelling regulations (No. 206/2012 and 626/2011), are competing with

other heating means. This includes, direct electric heating, larger than 12 kW air-to-air

heat pumps, but also water-based heating solutions.

From an end-user point of view, it would be easier if all these products competing on the

heating function could be compared directly, for instance using the same energy label or

energy class scale.

Above national differences, it should also be avoided that minimum performance

requirements and or different labelling scale lead to distort the heating market in a wrong

direction (i.e. leading to more energy consumption or CO2 emissions). For instance, to

excessively increase minimum efficiency requirement for air-to-air heat pumps could

significantly increase their price making those units less affordable. It could thus affect

their sales and make direct electric heating more economical for buildings with average to

low heat loads. The same might be true for consumers who consider replacing fossil fuel

boiler with air-to-air heat pumps at the time when heating system and generator need to

be replaced.

Ecodesign and Energy Labelling Directive only require impact assessment including

environmental impacts, costs and competitiveness within the same product group. As

competition exists between this various product groups that all have the same "space

heating" function, it is advised to include a supplementary dimension in the impact

assessment of future or revised Ecodesign and labelling regulations or to conduct a

dedicated study on the comparison of the proposed and existing regulations across the

different product groups that offer space heating.

7.6 Conclusions and recommendations

Policy options

Based on the assessment, the following policy options are chosen for further analysis:

• No action option – Business as usual (BAU), the current regulations are to be

retained as they are. This BAU scenario will be used as reference for comparison

with other policy scenarios.

51

• Ecodesign requirements (under the Ecodesign Directive (2009/125/EC)): Including

revised mandatory minimum requirements acting as a “push” instrument for

products to achieve better performance.

• Energy labelling (under the Energy Labelling Regulation (2017/1369/EU)28): This

implies a revised scale for mandatory labelling of the products’ efficiency.

Based in these policy options, six scenarios are modelled and are presented in Table 21.

Table 21: Summary of policy scenarios and brief descriptions

Policy

scenario

Description

Scenario 0

(0 BAU)

BAU before EU regulation – In general low yearly improvements. The only

improvement included is the use of inverter technology

Scenario 1

(1 BAU)

BAU scenario (current regulation) – The impact of the current regulation

with only limited incentive to improve products beyond the A+++ label

Scenario 2

(1 tier eco)

Ecodesign minimum efficiency requirement with one tier based on LLCC

(BC 1 for BC 1, -10%Ua_cond for BC 2 and HE1with R290for BC 3)

Scenario 3

(lbl)

Energy class A as BNAT (combining the different improvement for each

of the base cases)

Scenario 4

(eco+lbl)

Ecodesign and Energy labelling scenario 2 + scenario 3

Ecodesign requirements

The LLCC identified in the Task 6 is used for setting the immediate minimum requirement

for fixed air conditioners in ecodesign scenario 2. The BNAT level specify the energy class

A for energy labelling, only revised energy labelling regulation without revising ecodesign,

this is simulated in scenario 3. Scenario 4 represents the combination of the Ecodesign

requirements (scenario 2) and the Energy labelling (scenario 3).

The proposed ecodesign requirements and timing are presented in Table 22.

Table 22: Proposed minimum efficiency requirements for air conditioners in a potential revised ecodesign regulation

Tier 1, January 2023

SEER SCOP

Other than portable, < 6 kW 6 4

Other than portable, 6 – 12 kW 5.5 3.9

Portable 2.3 -

No SCOP minimum requirement is proposed for portable air conditioners. However, it is

proposed that ecodesign should include information requirement of SCOP using the

proposed metrics for portable on top of the existing minimum requirement on COP from

current regulation. It is also proposed to start the development of a new standard in line

with EN14825 plus infiltrations. With this potential new standard in place, portable products

will have to be adjusted to stay on the market. It is proposed that the portable would not

be allowed to operate in thermodynamic heating mode. Once performances of new double

duct products for new standard are known, then it can be evaluated how far their

performances should be increased.

28 Regulation (EU) 2017/1369 of the European Parliament and of the Council of 4 July 2017 setting a framework for energy labelling and repealing Directive 2010/30/EU

52

For portable air conditioners in general, it is recommended to have seasonal performance

metrics (SEER and SCOP) for setting requirements in the future.

Ecodesign requirement for comfort fans

Regarding comfort fans the same challenges still exist (since the preparatory study) and it

is further elaborated in Annex 1. Based on the findings of this assessment there are two

options which are:

• Setting minimum energy efficiency requirements on comfort fans with the

proposed requirements (from the preparatory study) with the risk of banning

many comfort fans in the European market (expected savings in the preparatory

study was slightly below 1 TWh).


gathering accurate information on comfort fan efficiency and test methods

through a complementary study/efficiency tests with corresponding costs.

Energy Labelling requirements

The proposed new label schemes are presented in Table 23 and Table 24. The label scheme

is based on the BNAT levels identified in Task 6 as the top level at energy class A. This

means that the best product currently available on the market only are able to achieve the

B class. This however does not apply to portable air conditioners, as products with

alternative refrigerants (as R410A will be banned after 2020) are not widely available and

it is difficult predict the refrigerant that will be used.

Table 23: Proposed new label schemes for SEER

Label scheme Other than portable air

conditioners

Portable air

conditioners

A SEER ≥ 11.5 SEER ≥ 4

B 9.7 ≤ SEER < 11.5 3.5 ≤ SEER < 4

C 8.1 ≤ SEER < 9.7 3.0 ≤ SEER < 3.5

D 6.8 ≤ SEER < 8.1 2.6 ≤ SEER < 3.0

E 5.7 ≤ SEER < 6.8 2.3 ≤ SEER < 2.6

F 4.8 ≤ SEER < 5.7 SEER < 2.3

G SEER < 4.8 Table 24: Proposed new label scheme for SCOP

Label

scheme

Other than portable air

conditioners

A SCOP ≥ 6.2

B 5.5 ≤ SCOP < 6.2

C 4.9 ≤ SCOP < 5.5

D 4.3 ≤ SCOP < 4.9

E 4.9 ≤ SCOP < 4.3

F SCOP < 3.8

G NA

It is the opinion of the study team that an energy class should only be proposed for portable

air conditioners in cooling mode using proposed SEER metrics in section 7.1.5. SCOP is to

be declared on the energy label but no energy class scale is proposed. When seasonal

performance (that accounts for infiltration) of these products is widely known, an energy

53

class scale for SCOP can be then proposed. A combined label is also being considered so

consumers can compare fixed and portable air conditioners.

A combined label can be based ηs,c and ηs,h and have the following classes presented in

Table 25. Ideally the label for heating should be aligned with other regulations so all

products/heaters can be compared.

Table 25: Proposed new label schemes for a combined label

Label scheme ηs,c ηs,h

A ηs,c ≥ 4.6 ηs,h ≥ 2.5

B 3.3 ≤ ηs,c < 4.6 2 ≤ ηs,h < 2.5

C 2.4 ≤ ηs,c < 3.3 1.6 ≤ ηs,h < 2

D 1.8 ≤ ηs,c < 2.4 1.3 ≤ ηs,h < 1.6

E 1.3 ≤ ηs,c < 1.8 1 ≤ ηs,h < 1.3

F 0.9 ≤ ηs,c < 1.3 0.8 ≤ ηs,h < 1

G ηs,c < 0.9 ηs,h < 0.8

Finally, infiltration measurement should be proposed in the future mandate for standards.

Tolerances and uncertainties have been assessed in earlier Tasks and two approaches

have been proposed to adjust tolerances. According to the previous definitions, the

tolerances should be higher than the repeatability measurement uncertainty alone and

lower or equal to the expanded uncertainty. In absence of Round Robin Tests, tolerance

values should be fixed to the maximum possible value, i.e. to the level of the maximum

expanded uncertainties.

With present measurement uncertainties, tolerance levels can be set as follows:


o SEER tolerance: 8 % below 2 kW cooling capacity, 6 % between 2 and 6 kW


o SCOP tolerance: 8 % below 2 kW cooling capacity, 7 % between 2 and 6 kW




units)



SEER and SCOP tolerance levels in Regulations (EU) No 206/2012 and 626/2011 need to

be revised accordingly.

With improved measurement accuracy, tolerances could be reduced to the following levels:


o SEER: 6 % below 6 kW cooling capacity and 4 % between 6 and 12 kW

o SCOP: 6 % below 6 kW cooling capacity and 4 % between 6 and 12 kW

54



Before EU regulations and BAU

Scenario 0 (before EU regulation) and scenario 1 (current BAU with EU regulations) show

that the current regulations have been effective and efficient, it is estimated that current

regulations (Ecodesign Regulation 206/2012 and Energy Labelling 626/2011) have

accumulatively by 2015 saved more than 138 TWh electricity and avoided more than 53

mt CO2-eq. It is expected that annual savings in period 2015 - 2020 is around 20 TWh

compared with consumptions before EU ecodesign and energy labelling regulations.

Sound power levels have also shown that the regulations have been effective, as the sound

power levels reported are kept below the maximum allowed levels when comparing data

from 2006 with the data from 2016. However, it is identified very limited further

improvement potential for sound power level if energy efficiency is to be continuously

increased.

Scenario analyses

Based on the newly proposed ecodesign requirements and labelling scheme, the impacts

of the different scenarios are modelled. The assessed impacts are electricity consumption,

primary energy and emission of CO2-eq. The annual impacts of the different scenarios in

2030 are presented in Table 26.

Table 26: The annual electricity consumption, emission of CO2-eq and associated savings in 2030

From the scenarios is it is visible that the largest savings are the combination of both

ecodesign requirements and the energy label with annual electricity saving of 3.5 TWh in

2030. The energy label alone has smaller impacts than the Ecodesign requirements in the

presented values, but for future reduction in the impacts the labelling scheme are

important to push for further improvements beyond 2030.

Table 27 shows the savings in 2040, as the revised regulations will have long-lasting effects

due to the continuous change of stock air conditioners to efficient new air conditioners, the

savings in 2040 are greater than those in 2030. Scenario 4 which combines ecodesign and

energy labelling is expected to yield 8 TWh electricity savings per year.

Scenario Electricity

(TWh)

Savings from

1 BAU (TWh)

Emission of

CO2-eq (mt)

Savings from 1

BAU (mt CO2-eq)

Scenario 0 (0 BAU) 83.3 - 35.2 -

Scenario 1 (1 BAU) 61.8 - 27.2 -


59.0 2.8 26.1 1.1

Scenario 3 (lbl)

60.3 1.5 26.6 0.6


58.3 3.5 25.9 1.3

55

Table 27: The annual electricity consumption, emission of CO2-eq and associated savings in 2040

The presented savings are supposedly even larger than the presented values as the

replacement of inefficient heaters due to more and more end-users operate reversible air

conditioners in heating mode are not accounted.

The sensitivity analysis showed that an improved recycling of the materials only will have

a limited impact regarding emission of CO2-eq, but this impact may not be a proper

measure for the material efficiency impacts. The leakage of refrigerant is important and

could pose a threat, but the f-gas regulation is already limiting the potential negative

impacts.

Due to the progressive development in efficiency to comply with ecodesign requirement

and energy labelling, the product price is expected to increase in the coming years, but

the extra costs will slowly reduce again over time. Overall, the consumer net expenditures

decrease in the scenarios with the highest efficiency, as energy costs savings offset the

increase in product price. In the future, the energy costs are even more important for the

consumers as the electricity prices are expected to increase.

The improved energy efficiency is not only beneficial for the consumers and the

environment but also for the industry. The industry is expected to grow and improve their

annual turnover and more persons are expected to work in air conditioner industry.

Material efficiency

Based on the assessment on possible material efficiency requirements for air conditioners,

as well as other studies for different product groups where possible material efficiency

requirements have been assessed, the following general conclusions are drawn:

• Ecodesign opportunity for material efficiency requirement for air conditioners exists

but the impact of such requirements is anticipated to be minimal without addressing

the issue at system level.

• EcoReport tool although has been revised in 2014, but it is not adequate for properly

assessing environmental impacts of material efficiency.

• Possible material efficiency requirements – even if they contribute to as high as

95% of recycling rate, the results from EcoReport Tool show that material efficiency

has only small impact in terms of the product’s entire LCA, this is due to that the

focus and the environmental indicators of the EcoReport Tool are mainly on energy,

for proper assessment, other environmental indicators should be included.

Scenario Electricity (TWh)

Savings from 1 BAU (TWh)

Emission of CO2-eq (mt)

Savings from 1 BAU (mt CO2-eq)

Scenario 0 (0 BAU) 115 - 48.2 -

Scenario 1 (1 BAU) 96 - 40.9 -


91.5 4.5 39.1 1.7

Scenario 3 (lbl)

89.3 6.7 38.3 2.6


87.6 8.4 37.6 3.2

56

• There could be synergies with DG Environment’s development of Product

Environmental Footprint (PEF). The methodology can be simplified and applied in

Ecodesign to assess other environmental impacts.

• Material efficiency of electrical and electronic products requires a system approach

within which the recycling processes, methods and facilities are addressed together

with product design. However, system approach of recycling processes, methods

and facilities is rather in the scope of WEEE directive than ecodesign.

• Furthermore, material efficiency is an issue that should be addressed at a horizontal

level, as per product group, the associated saving potential is low, but horizontally

across all electrical and electronic products, large savings potential can be achieved.

Therefore it may prove effective to align material efficiency requirements with other

regulations (such as for dishwasher, washing machines and domestic refrigerators

and freezers).

• Looking prospectively, to address the issue at a horizontal level, voluntary labelling

of recycled materials and minimum percentage used in product could be considered

as a policy model. FSC labelling approach from the European Union Timber

Regulation(EUTR) could be of inspiration.

• Unpredictable consequences and barriers exist for ecodesign requirements on

material efficiency that encourages reuse, as it is currently unclear who should take

on the ownership of a refurbished product and responsibility of the product’s safety.

Summary of suggestions

This section summarises the suggestions from Task 1 to Task 6.

• Ventilation exhaust air-to-air heat pumps and air conditioners ≤ 12 kW

It is advised to include these products in the scope of Regulation (EU) No

206/2012 and 626/2011 when their thermal power is below or equal to 12 kW and

to specify SEER and SCOP rating conditions and also to better specify which air is

used indoor and outdoor for air conditioners and heat pumps in Regulation (EU)

No 206/2012.

Test conditions proposed for SEER and SCOP determination of exhaust air-to-

outdoor air heat pumps and air conditioners are described in Task 1, Annex 1.

However, the latest update in April 2018 of this issue is that according to CEN TC

113 WG 7, it is not possible to develop a SEER/SCOP for these units. Without

SEER/SCOP, it is difficult to include these products in scope. The reason is that

these units are ventilation units where heat recovery is made by the heat pump

instead of being done by a heat recovery heat exchanger. The fact that these

units have two functions would make SCOP / SEER results not directly comparable

to the ones of other heat pumps. In other words they indeed supply capacity but

part of it might be supplied at an indoor temperature below 20 °C so capacity

related to heating (and so to Pdesignh declaration) is only a part of measured

capacity.

• Definition of a heat pump and air-to-air heat pump

The definition of a heat pump and air-to-air heat pump will also be added to the

regulation. The definitions will be adapted from Regulation (EU) No 2016/2281

and are described above in section 1.1.1.2.

57

• Residential fan heaters

It is recommended to include information requirement on the "air movement"

function of residential fan heaters in Regulation (EU) No 2015/1188 (similar to the

information requirement for comfort fans in Regulation 206/2012).

• Noise standards - EN 12102:2013

A draft version of this standard (prEN12102-2016) has been submitted for

approval with no major change identified. According to convenor of CEN TC 113 /

WG8, this standard could include rating conditions in the future. In order to link

SCOP value and sound power measurement in heating mode, it is planned to use

the point C in heating mode (outdoor air 7 °C / indoor air 20 °C / capacity 50 %)

in order to rate the sound power level of air conditioners in heating mode. This is

to be taken into account in any future regulation.

• EU Regulation 206/2012/EU - Ecodesign Requirements for air

conditioners and comfort fans

Regarding the calculation method, following input from test laboratories reported

in the description of standard EN14825 in Task 1 section 1.2.2, it is advised not to

allow performance tests to measure cycling performance degradation coefficients

Cdc and Cdh, but to use the default value 0.25 instead as there is no proof the

value can be measured satisfactorily for inverter units. However, in a possible

mandate to CEN for the revised regulation could emphasize the need to define

properly cycling tests for inverter units.

In the future, SEER and SCOP values should be replaced by primary energy

efficiency ratio in cooling and in heating mode following the example of more

recent regulations (e.g. Regulation (EU) No 2281/2016).

For heating only air-to-air heat pumps, it is also suggested that the test conditions

to measure sound power level in heating mode are specified. The planned test

conditions are heating mode point C in EN14825:2016 (outdoor air temperature +

7°C / declared capacity 50 %).

Finally, the crankcase hours should be changed from 2672 to 2363.

• Backup heater capacity

It is suggested to indicate the necessary additional backup heater capacity required

to reach Pdesignh even if it is not included in the unit. So it is proposed to require

the following additional information requirement under the naming "backup

heater":

o Required additional backup heater capacity: 3 values in kW to be supplied

for warm / average/cold climates; this corresponds to the difference

between Pdesignh for a specific climate and unit capacity of the unit at

Tdesignh;

o Backup heater included in the unit: Yes or No (3 values for the 3 different

climates).

• EU Regulation 1275/2008/EU - Ecodesign Requirements for standby and

off mode, and networked standby, electric power consumption of

electrical and electronic household and office equipment

It should be noted that air conditioners are not included in the standby regulation

but the requirements for standby in Regulation 206/2012 (with and without a

display) and off mode are in line with the standby regulation. Stakeholders have

58

raised the question whether air conditioners also should comply with the

requirements of networked standby and HiNA equipment. The standby

consumption is already included in the SEER calculation and leaves more room for

development for manufacturers. It is suggested that if the air conditioners are

networked by default, the networked standby consumption should be included in

the efficiency calculation instead of standby consumption, present standby hours

can be used.

• Low power mode hours

Low power mode hours have been reviewed. In the EN 14825:2016, the

crankcase heater consumption is measured in test condition D in both heating and

cooling mode, it means that for the average climate, there are two values for PCK,

and thus potentially also for PTO, PSB and POFF.

It is proposed to require two distinct crankcase power values for reversible

units, respectively for cooling mode - measured at 20 °C - and for heating mode -

measured at 12 °C. Cooling (or heating) only unit crankcase power measurement

should be done at 20 °C (12 °C), as already written in standard EN14825:2016.

Minor adjustments of crankcase hours are proposed, see above.

• Measurement of blown air temperature

It is proposed, for units in the scope of this study, to complete the data supplied

in test report of EN14511-3 with a measurement of the blown air temperature in

heating mode and blown air temperature and humidity in cooling mode. These

temperatures are normally measured during tests but not published. They should

be available in the technical documentation of the products for data collection

purpose. These values are to be reviewed at the time of the next revision of

Regulation 206/2012 and 626/2011 and evaluate the possible impacts and the

required changes in the standard and the regulation to ensure that SEER and

SCOP remain representative of real life. More details in Task 3, section 3.1.7.

• In situ continuous performance measurement

On-board measurement and others similar methods for in-situ continuous

performance measurement could be generalized and used by all manufacturers,

some of the manufacturers are already developing these methods themselves.

However, it is important to carry out standardization work to ensure their reliability.

This should include methods to correct performance evaluation for dynamic

conditions and the way faults are filtered, as well as possible checks of on-board

measurement capabilities by third parties. This is an important topic to improve

further the efficiency and to reduce real life consumption of air conditioners, as well

as to ensure that test standards are aligned with real life operating conditions as

regards sizing, equivalent full load hours and other operating hours.

• Additional information to end-user to reduce real life consumption

Another suggestion to cut real life energy consumption is to ensure continuous

monitoring. It is proposed to include the electricity consumption measurement in

the standardisation work to be done regarding in-situ continuous performance

measurement mentioned above. It is necessary to fix a certain number of

requirements (e.g. maximum uncertainty, minimum acquisition and averaging

times, test of the functionality in the unit based on standard tests).

• Testing information for set-up in technical documentation

59

It is thus proposed that testing information required to set up the machine to reach

claimed values be indicated in the technical documentation of the product, instead

of being provided upon request or to include it in the EU energy labelling database

(where it can only be accessed by market surveillance authorities). To make it

mandatory in the product information would also help the development of

competitive surveillance systems where manufacturers can check the claims of their

competitors.

60

Annex 1 – Comfort fans assessment

Sales

The sales of comfort fans in the preparatory study was based on data from PRODCOM. The

PRODCOM statistics are the official source for product data on the EU market. It is based

on product definitions that are standardised across the EU thus guaranteeing comparability

between Member States. Data are reported by Member States to Eurostat.

The PRODCOM statistics have some limitations given the complexities in the market and

so are they not always as detailed as necessary to support decision making within

ecodesign preparatory studies (e.g. data for air conditioners).

Within this study, the PRODCOM statistics are used to compare against product data

sourced from other data sources and expert assumptions in order to provide a higher

degree of confidence in the final product dataset. The product data sourced was used to

establish annual sales for product categories in scope, and subsequently for establishing

the installed base in the EU (i.e. stock).

PRODCOM EU sales and trade (i.e. the EU consumption) is derived by using the following

formula based on data from PRODCOM:

𝐸𝑈 𝑠𝑎𝑙𝑒𝑠 𝑎𝑛𝑑 𝑡𝑟𝑎𝑑𝑖𝑛𝑔 = 𝑝𝑟𝑜𝑑𝑢𝑐𝑡𝑖𝑜𝑛 + 𝑖𝑚𝑝𝑜𝑟𝑡 – 𝑒𝑥𝑝𝑜𝑟𝑡

For and comfort fans, the following PRODCOM categories have been used in the

preparatory study and the current study.

Table 28: Prodcom categories covering products relevant for this study.

PRODCOM code PRODCOM Nomenclature

27.51.15.30 Table, floor, wall, window, ceiling or roof fans, with a self-contained electric

motor of an output <= 125 W

Figure 25 illustrate the EU-28 production, import and export quantity according to the

current PRODCOM data for comfort fans below 125 W and Figure 26 shows the calculated

EU sales and trading for comfort fans below 125 W.

61

Figure 25: Total production, import and export quantity of comfort fans below 125 W 2009-2015. PRODCOM assessed April 2017.

Figure 26: Total EU sales and trading of comfort fans below 125 W 2009-2015. PRODCOM assessed April 2017.

From the current PRODCOM data the general tendency is a slight increase in the period

from 2009 to 2015. The sales and trading are expected to be highly connected with the

weather in the year concerned, so over a period of time one must expect some fluctuation

in the sales and trading. Since 2012 the EU sales and trading of comfort fans has increased

with an average increase of 5 % per year. This increase is highly connected with the

increase in import. The production and export of comfort fans only have minor fluctuation

over the years with an almost flat trend.

Since no other data has been available for comfort fans, PRODCOM data is used still used

in the current assessment. The assumptions made in the preparatory study assumed a

decrease in the annual sales. Current PRODCOM data presented in Figure 26 shows an

0

5,000,000

10,000,000

15,000,000

20,000,000

25,000,000

2009 2010 2011 2012 2013 2014 2015

Units

Prodcom production, import and export quantity of comfort fans <=125 W

Export Quantity, units

Import Quantity, units

Production Quantity, units

0

5,000,000

10,000,000

15,000,000

20,000,000

25,000,000

30,000,000

35,000,000

2009 2010 2011 2012 2013 2014 2015

Un

its

Prodcom EU sales and trades of comfort fans <=125 W

Sales and trades

62

increasing trend, but by expanding the timeframe it is possible to see a falling trend in the

current data as well. In Figure 27 the assumptions on EU sales and trading of comfort fans

in the preparatory study are compared with current PRODCOM data.

Figure 27: Comparison of EU sales and trading of comfort fans below 125 W 2009-2015 of current PRODCOM data (assessed April 2017) and expected sales and trades from the preparatory study

From the figure it is visible that the sales of comfort fans were expected to progressively

fall in the preparatory study (2 % per year due to the competition with air conditioners).

In reality the sales are very much dependent on the weather but overall the sales are

expected to fall. Based on the sales figures it is assumed that the data in the preparatory

study still are representative to the current situation despite the expected large

fluctuations. This means that the assumptions made on stock also is representative. The

stock in the preparatory study is presented in Figure 28.

Figure 28: Assumed stock development - preparatory study

0

5,000,000

10,000,000

15,000,000

20,000,000

25,000,000

30,000,000

35,000,000

40,000,000

45,000,000

50,000,000

2000 2005 2010 2015 2020 2025 2030

Un

its

Prodcom EU sales and trades of comfort fans <=125 W

Current prodcom data Preparatory study - assumptions

150000000

170000000

190000000

210000000

230000000

250000000

270000000

20

05

20

06

20

07

20

08

20

09

20

10

20

11

20

12

20

13

20

14

20

15

20

16

20

17

20

18

20

19

20

20

20

21

20

22

20

23

20

24

20

25

Sto

ck -

Un

its

63

The PRODCOM data does not distinguish between the different types of comfort fans but

this was also assessed in the preparatory study by internet and store surveys. The

distribution of comfort fan types is presented in Figure 29.

Figure 29: Types of comfort fans - assumption from the preparatory study

Tower fans, pedestal fans and table fans are the dominant type of fans based on the

internet and store survey in the preparatory study. This distribution of fan types is still

believed to be representative to the current situation.

Market overview

Based on data retrieved from topten29 it is possible to assess the current efficiency of

comfort fans on the European market. This data contained information on 158 models of

comfort fans that are presently available on the market. topten30 informed that the product

declaration was very poor despite the current information requirements. Of the whole

sample only 67 models declared sufficient information to assess the Service Value of the

products. For 8 models, the information was available on the retailer’s website. For the

remaining 137 models, the information on the service value and maximum fans flow rate

was not declared. This means that the consumers are buying comfort fans without the

knowledge of potential energy consumption. This also means that the consumers cannot

compare the different comfort fans regarding energy consumption.

The available data (75 comfort fans) are used to make the following figures. In Figure 30

is the distribution of wattage and service values presented and Figure 31 visualises the

spread in service values of the different types of comfort fans.

29 http://www.topten.eu/ 30 http://www.topten.eu/

Tower33%

Table29%

Pedestal29%

Ceiling3%

Box3%

Wall3%

Tower Table Pedestal Ceiling Box Wall

64

Figure 30: Spread in wattage and service values of comfort fans

Figure 31: Spread in service values of the different types of comfort fans

From the figures it is visible that the service value of comfort fans is very widespread, and

it is of special concern that very inefficient models are available on the European market.

For all types of fans, the difference of the most and least efficient fans are more than (0.5

m3/min)/W.

Despite the information requirements there is still a lack of data, which also was the case

during the preparatory study. In the impact assessment the following is stated:

“As to comfort fans, the heart of the issue is the lack of robust data on the performance of

fans sold in the EU. The preparatory study recognised this problem and proposed as

possible solution the setting of minimum efficiency (and noise) requirements as applied in

China and Taiwan. These values were thought to be attainable (since applied in the

manufacturing country of origin for comfort fans) leading close to 1 TWh/a savings by

2020.

0

0.5

1

1.5

2

2.5

3

3.5

4

4.5

0 20 40 60 80 100 120 140

Serv

ice

Val

ue

(m3

/min

)/W

Watt

Ceiling

Floor

Standing

Table

Tower

65

However, during the impact assessment study it became apparent that the results of fan

efficiency established using IEC 60879 are not compatible with the Chinese requirements.

Additional input from stakeholders and experts revealed that there is no certainty to what

actual measurement standards are applied when the performance of fans is declared and

whether the fans actually meet the Chinese requirements. This removed the basis for the

proposal to introduce minimum efficiency requirements in line with the Chinese legislation.

In the second Consultation Forum meeting three options were considered:

1) Setting efficiency requirements at similar level as in China/Taiwan with risk of

removing virtually all comfort fans from the EU market;

2) Setting requirements at lower levels than proposed in the preparatory study with

loss of savings potential. However, the insufficiency of data and test results would

result in 'blindly-set' requirements with corresponding risk of lost savings or banning

of appliances;

3) Setting information requirements only for the indication of the measured efficiency

of the appliance and the measurement method used. Savings would be postponed

until the setting of minimum efficiency and/or labelling requirements, but the

information requirements would help supporting national authorities in their market

surveillance activities and provide sound basis for energy efficiency data for any

future measures. Information requirements will not lead to any considerable

administrative burden, as the efficiency tests will provide this information for each

model anyway. While today appliances include information based on EER and COP,

they will include information based on SEER and SCOP after the coming into force

of requirements.

The third option was chosen, as options 1 and 2 were considered unacceptably risky. As

the setting of product information requirements is not estimated to differ significantly from

the baseline scenario in terms of costs against the obvious benefits, this option is not

further analysed.”

The available standard is still IEC 60879 so there is a still a risk that service values not are

comparable across borders. This makes it very difficult to suggest any reasonable

requirements as the efficiency on the market is unknown. Furthermore, the standard does

not include tower fans which are assumed to cover 33 % of the market.

By implementing the MEPS suggested in the preparatory study the concern was that

comfort fans were banned from the market. The suggested minimum requirements in the

preparatory study are presented in Table 29.

66

Table 29: Suggested minimum requirements in the preparatory study

Fan type Fan diameter (cm)

Service value minimum acceptable ((m3/min)/W)

Maximum acceptable noise (dB(A))

Tower

fans 0-20 0.54 59

All

comfort

fans

except

tower

and

ceiling

20-23 0.54 59

23-25 0.64 60

25-30 0.74 61

30-35 0.81 63

35-40 0.9 65

40-45 1 67

45-50 1.1 68

50-60 1.13 70

60+ 1.3 73

Ceiling

fans

0-60 0.54 62

60-90 0.87 62

90-120 1.15 65

120-130 1.46 67

130-140 1.45 70

140-150 1.45 72

150+ 1.47 75

Whether these requirements still are assumed to ban comfort fans from the market is

unknown. The available data is not divided in fan diameter and since there is a clear link

between fan diameter and obtainable service value it is difficult to suggest new

requirements based on data currently available.

Instead of assessing fans based on their fan diameter the requirements could be dependent

on the type. This may mean that small comfort fans (small diameter) are banned from the

market. These requirements could be based on the LLCC found in the preparatory study.

The LLCC and BAT found in the preparatory study are presented in

Table 30: LLCC and BAT for different types of comfort fans - based on the preparatory study LLCC BAT

Service Values for Table fans ((m3/min)/Watt) 1 1.77

Service Values for Pedestal fans ((m3/min)/Watt) 1 1.77

Service Values for Tower fans ((m3/min)/Watt) 1.5 2.2

67

Figure 32: LLCC from the preparatory study and current service value.

From the figure it seems like the majority of the table fans currently not even are able to

reach the LLCC level from the preparatory study. This means that there has been very little

technological development on comfort fans in Europe. Most comfort fans are also low

priced, so this may affect the possibilities for further improvement. The lack of

improvement in Europe may also be due to the lack of requirements so all the inefficient

comfort fans are shipped to Europe. Topten have informed that it seems like comfort fans

in e.g. china are more efficient than in Europe.

Impact of requirements

If any minimum requirements are suggested it is unknown how this will affect the market

due to the inconsistencies with standards (Europe/Asia) and also the lack of data. If the

service value in Europe and Asia is comparable there is room for improvement. The most

efficient comfort fans are present in China and India. This is based on the topten list

requirements in Asia. The service value requirements to reach the topten list in China are

presented in table

Construction type Energy efficiency value (m3/min/W)

Standing ≥ 1.31

Ceiling ≥ 3.08

Other ≥ 1.40

The presented threshold values in China are considered weak, but if these threshold values

are adopted to Europe it seems difficult for topten to populate the list. Though, there is

still the uncertainty regarding standards. So, it is unknown whether comfort fans in China

are rated better due to differences in the standard or lack in control.

So overall the same challenges still exist regarding requirements for comfort fans and the

following two options from the impact assessment is still valid to consider:

• Setting minimum energy efficiency requirements on comfort fans with the proposed

requirements (from the preparatory study) with the risk of banning many comfort

0

0.5

1

1.5

2

2.5

3

3.5

4

4.5

0 20 40 60 80 100 120 140

Serv

ice

Val

ue

(m3

/min

)/W

Watt

Ceiling

Floor

Standing

Table

Tower

LLCC tower

LLCC table/pedestal/

standing/floor

68

fans in the European market (expected savings in the preparatory study was slightly

below 1 TWh).


gathering accurate information on comfort fan efficiency and test methods through

a complementary study/efficiency tests with corresponding costs.

69

Annex 2 – Policy scenarios assumptions

All scenarios consist of a set of assumptions that are fixed which are presented in the table

below.

Table 31: Assumptions in all scenarios

Cooling

capacity kW

Cooling

hours

Pdesignh

(kW)

Leakage

rate

BC 1 3.5 350 3 3%

BC 2 7.1 350 6.5 3%

BC 3 2.6 1%

All scenarios also consist of some values that are changing due to annual development.

Though are these assumptions alike in all scenarios. These assumptions are:

• Assumptions for hours in heating:

o 0 hours in 1992 to 700 hours in 2015 (linear regression until full load hours

are reached in 2038 for new products)

• Assumptions for refrigerant:

o R410 until ban, then R-32 for fixed and propane for portable. For fixed air

conditioners there is a linear regression in the conversion from R410 until

the ban. This means that the GWP will gradually decrease until the ban.

70

Annex 3 – Tables and figures

This annex presents additional tables and figures to support the analysis in this report.

Development of SEER and SCOP average sales values in the different policy options

The assumed SEER and SCOP development for the different policy options are presented

in the table below.

Table 32: Development of SEER and SCOP average sales values in the different scenarios.

2010 2015 2020 2025 2030 2035 2040


SEER

BC1 4.81 6.00 6.73 7.38 7.61 7.83 8.05

BC2 4.58 5.80 6.21 6.59 6.73 6.87 7.01

BC3 1.65 1.83 2.08 2.33 2.37 2.42 2.46

SCOP

BC1 3.34 4.00 4.19 4.36 4.47 4.58 4.69

BC2 3.26 4.00 4.10 4.19 4.25 4.31 4.38

BC3 - - - - - - -

Scenario 3 (lbl)

SEER

BC1 4.81 6.00 6.36 6.88 7.44 8.01 8.57

BC2 4.58 5.80 6.01 6.31 6.63 6.95 7.26

BC3 1.65 1.83 1.87 2.17 2.54 2.90 3.27

SCOP

BC1 3.34 4.00 4.09 4.27 4.47 4.67 4.88

BC2 3.26 4.00 4.04 4.17 4.31 4.45 4.60

BC3 - - - - - - -

Scenario 4 (eco+lbl)

SEER BC1 4.81 6.00 6.73 7.51 7.95 8.39 8.83

BC2 4.58 5.80 6.21 6.65 6.90 7.15 7.40

BC3 1.65 1.83 2.08 2.48 2.79 3.09 3.39

SCOP BC1 3.34 4.00 4.19 4.41 4.58 4.76 4.93

BC2 3.26 4.00 4.10 4.23 4.36 4.49 4.62

BC3 - - - - - - -

Environmental impacts of the different scenarios for each of the base cases

Figure 33: Comparison of impacts of the different scenarios – Primary energy (PJ) in absolute values

350

450

550

650

750

850

950

1050

1150

2010 2015 2020 2025 2030 2035 2040

PJ

(Pri

mar

y en

ergy

)

Scenario 0(0 BAU)

Scenario 1(1 BAU)


Scenario 3(lbl)


71

Figure 34: Comparison of impacts of the different scenarios – Emission of CO2 (Mt) in absolute values

Table 33: Impacts of scenario 0 (before regulation) - TWh, Primary energy and CO2-eq in absolute values

2010 2015 2020 2025 2030 2035 2040

Scenario 0 (current regulation)

TWh (Electricity)

BC1 37.9 38.7 36.4 42.6 52.2 62.7 75.3

BC2 19.6 22.7 22.4 25.3 29.3 33.7 38.7

BC3 1.2 1.1 1.0 1.0 1.0 1.0 1.0

Total 58.6 62.6 59.8 69.0 82.6 97.4 115.0

PJ (Primary energy)

BC1 354.4 360.2 341.8 400.9 490.0 587.5 704.8

BC2 184.0 213.0 210.7 238.4 275.5 316.4 362.7

BC3 12.5 11.9 10.9 11.0 10.9 11.0 11.0

Total 551.0 585.1 563.4 650.2 776.4 914.9 1078.5

Mt CO2-eq

BC1 17.4 17.6 16.5 18.7 22.2 26.3 31.5

BC2 9.0 10.4 10.2 11.2 12.5 14.2 16.2

BC3 0.6 0.6 0.5 0.5 0.5 0.5 0.5

Total 27.1 28.6 27.2 30.4 35.2 40.9 48.2

Table 34: Impacts of scenario 1 (current regulation) - TWh, Primary energy and CO2-eq in absolute values

2010 2015 2020 2025 2030 2035 2040


TWh

(Electricity)

BC1 30.4 28.4 25.3 30.7 40.2 51.2 64.1

BC2 14.7 15.1 14.0 16.6 20.8 25.7 31.1

BC3 1.0 0.9 0.8 0.8 0.8 0.8 0.8

Total 46.2 44.5 40.2 48.1 61.8 77.7 96.0

PJ (Primary energy)

BC1 287.6 267.4 242.5 293.9 381.7 484.2 603.6

BC2 140.0 144.5 135.5 159.4 198.4 244.1 293.9

BC3 11.4 10.3 9.1 9.1 9.2 9.3 9.4

Total 439.1 422.2 387.1 462.4 589.3 737.5 906.9

Mt CO2-eq

BC1 14.6 13.6 12.2 14.2 17.6 21.9 27.2

BC2 7.1 7.5 7.0 7.8 9.2 11.1 13.3

BC3 0.6 0.5 0.4 0.4 0.4 0.4 0.4

Total 22.3 21.6 19.6 22.4 27.2 33.4 40.9

15

20

25

30

35

40

45

50

2010 2015 2020 2025 2030 2035 2040

Mt

CO

2-e

q

Scenario 0(0 BAU)

Scenario 1(1 BAU)


Scenario 3(lbl)

Scenario 4(eco+lbl)

72

Table 35: Impacts of scenario 2 (1 tier eco) - TWh, Primary energy and CO2-eq in absolute values

2010 2015 2020 2025 2030 2035 2040


TWh (Electricity)

BC1 30.4 28.4 25.2 29.7 38.2 48.6 60.7

BC2 14.7 15.1 14.0 16.3 20.2 24.9 30.0

BC3 1.0 0.9 0.8 0.7 0.7 0.7 0.7

Total 46.2 44.5 40.0 46.7 59.0 74.1 91.5

PJ (Primary

energy)

BC1 287.6 267.4 241.1 285.0 363.6 460.1 573.9

BC2 140.0 144.5 135.1 156.7 193.0 236.8 284.8

BC3 11.4 10.3 9.0 8.3 7.9 8.0 8.1

Total 439.1 422.2 385.2 450.1 564.5 704.9 866.8

Mt CO2-eq

BC1 14.6 13.6 12.2 13.8 16.8 20.9 25.9

BC2 7.1 7.5 6.9 7.7 9.0 10.8 12.9

BC3 0.6 0.5 0.4 0.4 0.4 0.4 0.4

Total 22.3 21.6 19.6 21.8 26.1 32.0 39.1

Table 36: Impacts of scenario 3 (lbl) - TWh, Primary energy and CO2-eq in absolute values

2010 2015 2020 2025 2030 2035 2040

Scenario 3 (lbl)

TWh (Electricity)

BC1 30.4 28.4 25.3 30.5 39.2 48.7 59.5

BC2 14.7 15.1 14.0 16.5 20.3 24.7 29.2

BC3 1.0 0.9 0.8 0.8 0.7 0.6 0.6

Total 46.2 44.5 40.2 47.8 60.3 74.0 89.3

PJ (Primary energy)

BC1 287.6 267.4 242.5 292.2 372.9 461.8 562.5

BC2 140.0 144.5 135.5 158.7 194.8 234.9 277.2

BC3 11.4 10.3 9.1 8.9 8.2 7.5 7.0

Total 439.1 422.2 387.1 459.7 575.9 704.2 846.8

Mt CO2-eq

BC1 14.6 13.6 12.2 14.1 17.2 20.9 25.4

BC2 7.1 7.5 7.0 7.8 9.1 10.7 12.6

BC3 0.6 0.5 0.4 0.4 0.4 0.3 0.3

Total 22.3 21.6 19.6 22.3 26.6 32.0 38.3

Table 37: Impacts of scenario 4 (eco+lbl) - TWh, Primary energy and CO2-eq in absolute values

2010 2015 2020 2025 2030 2035 2040


TWh (Electricity)

BC1 30.4 28.4 25.2 29.7 37.7 47.2 58.2

BC2 14.7 15.1 14.0 16.2 19.9 24.2 28.9

BC3 1.0 0.9 0.8 0.7 0.6 0.6 0.5

Total 46.2 44.5 40.0 46.6 58.3 72.0 87.6

PJ (Primary energy)

BC1 287.6 267.4 241.1 284.4 359.3 448.1 550.8

BC2 140.0 144.5 135.1 156.4 191.0 231.1 274.1

BC3 11.4 10.3 9.0 8.2 7.4 7.0 6.7

Total 439.1 422.2 385.2 449.0 557.7 686.2 831.6

Mt CO2-eq

BC1 14.6 13.6 12.2 13.8 16.6 20.3 24.9

BC2 7.1 7.5 6.9 7.7 8.9 10.5 12.4

BC3 0.6 0.5 0.4 0.4 0.3 0.3 0.3

Total 22.3 21.6 19.6 21.8 25.9 31.2 37.6

73

The accumulated savings

The accumulated energy savings compared to scenario 1 (the current regulation) are

presented in the table below.

Table 38: The accumulated savings in energy and emission of CO2-eq of the policy options compared to the current regulation (scenario 1)

1995 2000 2005 2010 2015 2020 2025 2030 2035 2040



0 0 0 0 0 0 5 16 32 53

Scenario 3 (lbl)

0 0 0 0 0 0 1 5 19 46


0 0 0 0 0 0 5 18 42 79

Primary energy consumption (PJ)


0 0 0 0 0 0 5 47 171 415

Scenario 3 (lbl)

0 0 0 0 0 3 44 163 380 707


0 0 0 0 0 0 5 47 171 415

mt CO2-eq Scenario 2

(1 tier eco) 0 0 0 0 0 0 2 6 12 20

Scenario 3 (lbl)

0 0 0 0 0 0 0 2 7 18

Scenario 4

(eco+lbl) 0 0 0 0 0 0 2 7 16 30

Figure 35: The accumulated savings in primary energy (PJ)of the policy options compared to the current regulation (scenario 1)

0

100

200

300

400

500

600

700

800

2015 2020 2025 2030 2035 2040

Pri

mary

energ

y (

PJ)

Scenario 2a

(1 tier eco)

Scenario 3

(lbl)

Scenario 4a

(eco+lbl)

74

Development of purchase price per unit in different policy options

Table 39: Development in purchase price per unit in absolute values

2010 2015 2020 2025 2030 2035 2040


EUR

BC1 492 509 517 520 517 509 472

BC2 1114 1157 1182 1191 1188 1174 1088

BC3 259 243 228 213 199 186 170


EUR

BC1 737 830 795 759 723 686 650

BC2 1799 2059 1929 1806 1689 1577 1472

BC3 308 307 284 263 243 225 208


EUR

BC1 737 830 842 835 777 723 673

BC2 1799 2059 1994 1910 1764 1628 1502

BC3 308 307 316 320 295 271 250

Scenario 3 (lbl)

EUR BC1 737 830 795 778 761 740 716

BC2 1799 2059 1929 1830 1738 1646 1556

BC3 308 307 284 298 315 326 332


EUR BC1 737 830 842 849 813 775 737

BC2 1799 2059 1994 1928 1809 1694 1585

BC3 308 307 316 341 346 347 344

Consumer impacts for each of the base cases in absolute values

Table 40: Annual consumer purchase costs of air conditioners in absolute values

2010 2015 2020 2025 2030 2035 2040


Billion

EUR

BC1 1.53 1.32 1.69 2.04 2.34 2.66 2.89

BC2 0.85 0.96 1.06 1.22 1.37 1.50 1.55

BC3 0.15 0.14 0.10 0.10 0.09 0.09 0.09

Total 2.53 2.42 2.85 3.36 3.8 4.25 4.53


Billion EUR

BC1 2.29 2.16 2.60 2.99 3.27 3.58 3.98

BC2 1.38 1.70 1.74 1.85 1.94 2.02 2.10

BC3 0.18 0.17 0.13 0.12 0.12 0.11 0.10

Total 3.85 4.03 4.47 4.96 5.33 5.71 6.18


Billion EUR

BC1 2.29 2.16 2.76 3.28 3.52 3.77 4.11

BC2 1.38 1.70 1.80 1.96 2.03 2.09 2.14

BC3 0.18 0.17 0.14 0.15 0.14 0.13 0.13

Total 3.85 4.03 4.7 5.39 5.69 5.99 6.38

Scenario 3 (lbl)

Billion EUR

BC1 2.29 2.16 2.60 3.06 3.45 3.86 4.38

BC2 1.38 1.70 1.74 1.88 2.00 2.11 2.22

BC3 0.18 0.17 0.13 0.14 0.15 0.16 0.17

Totals 3.85 4.03 4.47 5.08 5.6 6.13 6.77


Billion EUR

BC1 2.29 2.16 2.76 3.34 3.68 4.04 4.51

BC2 1.38 1.70 1.80 1.98 2.08 2.17 2.26

BC3 0.18 0.17 0.14 0.16 0.16 0.17 0.17

Totals 3.85 4.03 4.7 5.48 5.92 6.38 6.94

75

Table 41: Annual consumer electricity costs in absolute values

2010 2015 2020 2025 2030 2035 2040


Billion EUR

BC1 6.3 7.1 7.1 8.6 10.7 13.2 15.7

BC2 3.2 4.1 4.3 5.1 5.9 7.0 8.0

BC3 0.2 0.2 0.2 0.2 0.2 0.2 0.2

Total 9.7 11.4 11.7 13.9 16.9 20.4 23.9


Billion EUR

BC1 5.1 5.2 5.0 6.2 8.3 10.8 13.4

BC2 2.4 2.7 2.7 3.3 4.2 5.3 6.4

BC3 0.2 0.2 0.2 0.2 0.2 0.2 0.2

Total 7.7 8.1 7.9 9.7 12.6 16.3 19.9


Billion

EUR

BC1 5.1 5.2 4.9 6.0 7.8 10.2 12.7

BC2 2.4 2.7 2.7 3.2 4.1 5.2 6.2

BC3 0.2 0.2 0.2 0.1 0.1 0.1 0.1

Total 7.7 8.1 7.8 9.4 12.1 15.5 19.0

Scenario 3 (lbl)

Billion EUR

BC1 5.1 5.2 5.1 6.1 8.2 10.2 12.5

BC2 2.4 2.7 2.7 3.3 4.1 5.2 6.1

BC3 0.2 0.2 0.2 0.2 0.1 0.1 0.1

Totals 7.7 8.1 7.9 9.6 12.4 15.5 18.7


Billion EUR

BC1 5.1 5.2 5.0 5.9 7.9 9.9 12.2

BC2 2.4 2.7 2.7 3.2 4.0 5.1 6.1

BC3 0.17 0.16 0.16 0.14 0.12 0.12 0.11

Totals 7.7 8.1 7.9 9.3 12.0 15.1 18.4

Table 42: Annual installation and maintenance costs in absolute values

2010 2015 2020 2025 2030 2035 2040

All scenarios – installation

Billion EUR

BC1 1.5 1.8 3.3 2.5 2.1 2.6 3.1

BC2 0.3 0.4 0.7 0.6 0.7 0.7 0.8

BC3 0.0 0.0 0.0 0.0 0.0 0.0 0.0

Total 1.8 2.1 4.0 3.1 2.7 3.3 4.0

All scenarios – maintenance

Billion EUR

BC1 0.2 0.2 0.3 0.3 0.2 0.3 0.3

BC2 0.0 0.0 0.1 0.1 0.1 0.1 0.1

BC3 0.0 0.0 0.0 0.0 0.0 0.0 0.0

Totals 0.2 0.2 0.4 0.3 0.3 0.4 0.4

Industry impacts

The Industry impacts are presented in the table below.

Table 43: Industry impacts - Manufacturer turnover (Mln EUR)

2010 2015 2020 2025 2030 2035 2040

Manufacturer turnover (Mln EUR)

Scenario 0 (0 BAU) 1160 1106 1301 1527 1724 1926 2046

Scenario 1 (1 BAU) 1755 1838 2029 2248 2417 2585 2794

Scenario 2 (1 tier eco) 1755 1838 2132 2445 2581 2715 2887

Scenario 3 (lbl)

1755 1838 2029 2302 2540 2779 3065

Scenario 4

(eco+lbl)

1755 1838 2132 2485 2690 2896 3145

76

Table 44: Industry impacts - Manufacture total personnel (Persons)

2010 2015 2020 2025 2030 2035 2040

Manufacture total personnel (Persons)

Scenario 0 (0 BAU) 3356 3197 3764 4415 4986 5570 5918

Scenario 1

(1 BAU) 5075 5316 5867 6501 6988 7476 8079


Scenario 3 (lbl) 5075 5316 5867 6656 7344 8038 8863

Scenario 4 (eco+lbl) 5075 5316 6166 7187 7780 8374 9096

Table 45: Industry impacts - OEM total personnel (Persons)

2010 2015 2020 2025 2030 2035 2040

OEM total personnel (Persons)

Scenario 0

(0 BAU) 4027 3837 4516 5298 5984 6684 7102

Scenario 1 (1 BAU) 6090 6380 7041 7801 8386 8971 9694


Scenario 3 (lbl) 6090 6380 7041 7988 8813 9646 10636

Scenario 4 (eco+lbl) 6090 6380 7400 8624 9337 10049 10916

Table 46: Industry impacts - OEM total personnel – EU (Persons)

2010 2015 2020 2025 2030 2035 2040

OEM total personnel – EU (Persons)

Scenario 0 (0 BAU) 805 767 903 1060 1197 1337 1420

Scenario 1 (1 BAU) 1218 1276 1408 1560 1677 1794 1939


Scenario 3 (lbl) 1218 1276 1408 1598 1763 1929 2127

Scenario 4 (eco+lbl) 1218 1276 1480 1725 1867 2010 2183

Table 47: Industry impacts - Wholesaler turnover (Mln EUR)

2010 2015 2020 2025 2030 2035 2040

Wholesaler turnover (Mln EUR)

Scenario 0 (0 BAU) 348 332 390 458 517 578 614

Scenario 1 (1 BAU) 526 552 609 674 725 776 838


Scenario 3 (lbl) 526 552 609 691 762 834 919

Scenario 4a (eco+lbl) 526 552 640 746 807 869 944

77

Table 48: Industry impacts - Wholesaler total personnel (Persons)

2010 2015 2020 2025 2030 2035 2040

Wholesaler total personnel (Persons)

Scenario 0 (0 BAU) 683 651 766 899 1015 1134 1205

Scenario 1 (1 BAU) 1033 1082 1194 1323 1423 1522 1644


Scenario 3 (lbl) 1033 1082 1194 1355 1495 1636 1804

Scenario 4a (eco+lbl) 1033 1082 1255 1463 1584 1705 1852

Sensitivity analysis in absolute values

Table 49: The calculated impacts of higher levels of recycling and the effect of higher leakage in absolute values.

2010 2015 2020 2025 2030 2035 2040


Mt CO2-eq

BC1 14.6 13.6 12.2 13.8 16.6 20.3 24.9

BC2 7.1 7.5 6.9 7.7 8.9 10.5 12.4

BC3 0.6 0.5 0.4 0.4 0.3 0.3 0.3

Total 22.3 21.6 19.6 21.8 25.9 31.2 37.6

Sensitivity (95% recycling)

Mt CO2-eq

BC1 14.5 13.6 12.1 13.6 16.5 20.2 24.7

BC2 7.1 7.4 6.9 7.6 8.8 10.4 12.3

BC3 0.5 0.5 0.4 0.4 0.3 0.3 0.3

Total 22.1 21.5 19.4 21.6 25.6 30.9 37.3

Sensitivity (Double leakage)

Mt CO2-eq

BC1 17.5 16.5 14.5 15.7 18.1 21.6 26.4

BC2 8.6 9.1 8.4 8.8 9.7 11.2 13.2

BC3 0.6 0.5 0.5 0.4 0.3 0.3 0.3

Total 26.7 26.2 23.4 24.9 28.1 33.2 39.9

Task 7 report SCENARIOS · 2019-10-29 · Task 7 report SCENARIOS Final version Date: May 2018 . 2...

Documents

Transcript of Task 7 report SCENARIOS · 2019-10-29 · Task 7 report SCENARIOS Final version Date: May 2018 . 2...